May U.S. insurers issue policies and pay claims related to group health, life, and travel insurance on behalf of third-country nationals traveling to or within Cuba?
OFAC's answer
Yes, provided that the insurance policy is a global policy, and not specific to the third-country national’s travel to or within Cuba. Section [515.580](https://gov.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.580) of the CACR authorizes persons subject to U.S. jurisdiction to issue or provide global health, life, or travel insurance policies for individuals ordinarily resident in a country outside of Cuba who travel to or within Cuba, regardless of whether the insurance policy is issued only to that individual or to a group, such as to all employees of a particular company. For instance, a U.S. insurer may pay medical claims pursuant to a group health insurance policy to or on behalf of a covered third-country national injured while traveling in Cuba. However, this provision does not authorize a person subject to U.S. jurisdiction to issue an insurance policy that is specific to travel to Cuba. A separate provision of the CACR, § 515.560, authorizes the provision of health, life, and travel insurance-related services that are specific to Cuba for authorized U.S. travelers. Also, effective September 24, 2020, OFAC amended § [515.560](https://gov.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.560) to exclude from the authorization at § 515.560(c)(2) lodging, paying for lodging, or making any reservation for or on behalf of a third party to lodge, at any property in Cuba on the Cuba Prohibited Accommodations List to the extent prohibited by § 515.210. For a complete description of the scope of this prohibition, see 31 CFR § 515.210.