OFAC FAQ #775 · Cuba Sanctions
May U.S. insurers, either directly or through third-country subsidiaries, issue policies, or pay insurance or reinsurance claims related to non-U.S. persons providing goods or services that facilitate travel by third-country nationals from a third country to Cuba?
OFAC's answer
Other than certain global health, life, or travel insurance policies for individuals authorized by [31 CFR § 515.580](https://gov.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.580), absent specific authorization from OFAC, U.S. insurers and their subsidiaries are not permitted to issue policies, provide reinsurance coverage, or pay insurance or reinsurance claims related to non-U.S. persons, including entities such as foreign airlines, providing goods or services that facilitate travel by third-country nationals from a third country to Cuba.