OFAC FAQ #776 · Cuba Sanctions
Are health, life, or travel insurance policies that are issued to a “group” (e.g., an employer and its employees) authorized by the CACR?
OFAC's answer
[Section 515.580 of the CACR](https://gov.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-515/subpart-E/section-515.580) authorizes global health, life, or travel insurance policies covering individuals ordinarily resident in a country outside of Cuba traveling to Cuba. The policy may be issued to a group, such as all employees of a company. The “global” requirement means it cannot be specific to travel to Cuba. For example, it does not authorize an individual travel policy issued to a traveler specifically to cover a trip to Cuba. It also does not authorize issuing a policy to a non-U.S. travel agent specifically to cover its traveler clients where the travel agency is solely in the business of planning trips to Cuba.