Can an insurer offer global travel insurance and worldwide travel assistance without violating U.S. sanctions?
The provision of all travel related services are authorized for all OFAC country sanctions programs (including Burma, Iran and Sudan) except Cuba. Travel related services may only be provided in Cuba pursuant to a valid general or specific OFAC license. If the traveler is a U.S. person traveling to Cuba pursuant to a valid OFAC license, travel insurance may be issued to the traveler by a U.S. insurer without a separate license. While there are some instances when U.S. persons travel to Cuba without a valid license (and thus pose sanctions problems for U.S. travel insurers), U.S. travel insurance providers most frequently face sanctions problems when they offer travel insurance products to third country nationals traveling to Cuba. In such cases the U.S. insurer must obtain a license to issue the travel insurance product. Additionally, insurers must also be sure to check OFAC’s list of Specially Designated Persons to ensure that no services of any kind are rendered to persons or entitie