Representative Ileana Ros-Lehtinen is seeking to use a politically biased evaluation system of sex-trafficking to pressure the Administration to retreat from its important, albeit bureaucratically constipated, opening of purposeful travel.

Ros-Lehtinen wrote Secretary of State Clinton, no doubt seeking to appeal to her well known concern for a pervasive international problem:

I would urge the administration, within all applicable rules and guidelines, to reverse its current policy and suspend all educational and cultural exchanges with the Cuban regime pursuant to the Trafficking Victims Protection Act of 2000.

According to U.S. law, “countries on Tier 3 may not receive funding for government employees’ participation in educational and cultural exchange programs.”

The substance of Cuba’s ranking in the trafficking score card is about as real, and is as politically motivated, as the justification for keeping Cuba on the list of State Sponsors of Terrorism.  From the State Department report:

Cuba is a source country for adults and some children subjected to forced labor and sex trafficking. Some Cuban medical professionals assigned to work abroad have claimed that their passports were retained as a means of keeping them in a state of exploitation, thus preventing them from traveling freely.* … The scope of trafficking within Cuba is particularly difficult to gauge due to the closed nature of the government and sparse non-governmental or independent reporting…..

Cuba appears to prohibit most forms of trafficking activity through various provisions of its penal code; however, the use of these provisions could not be verified, and prostitution of children over the age of 16 is legal, leaving children over 16 particularly vulnerable to commercial sexual exploitation. The government did not share official data relating to Cuban investigations, prosecutions, and convictions of trafficking offenders, including any officials complicit in human trafficking, in 2010 or any other year. The government did not report any anti-trafficking training provided to officials.

The government did not publicize official data on protection of trafficking victims during the reporting period. The government did not report any procedures in place to guide officials in proactively identifying trafficking victims in vulnerable groups (such as people in prostitution) and referring them to available services. The government operates at least two well-regarded facilities for the treatment of children who have been sexually and physically abused. In addition, the government operates a nationwide network of shelters for victims of domestic violence or child abuse, but the government did not verify if trafficking victims received treatment in these centers.

Cuba’s main problem seems to be that it does not check off the right bureaucratic boxes, probably because as noted in the report, "Cuba is not a party to the 2000 UN Trafficking in Persons Protocol."