Frequently Asked Questions

777. May persons subject to U.S. jurisdiction provide certain insurance-related services (such as cargo or hull insurance, or reinsurance) to persons subject to U.S. jurisdiction who are engaging in authorized activity in Cuba?

Answer

Where the provision of insurance-related services is directly incident to activity authorized by general or specific license, then the provision of such services is authorized as well. For example, § 515.566 of the CACR authorizes travel and travel-related transactions directly incident to engaging in religious activities in Cuba. The provision of health insurance-, life insurance-, and travel insurance-related services to authorized travelers traveling to Cuba pursuant to § 515.566 would be authorized. For additional information, see Note 2 to 31 CFR § 515.560. As an additional example, the provision of insurance to a person subject to U.S. jurisdiction that is incident to convening authorized athletic competitions, as defined in 31 CFR § 515.567(a), would also be authorized.

Additionally, § 515.533 of the CACR authorizes transactions ordinarily incident to the exportation or reexportation to Cuba of certain goods licensed or otherwise authorized by the Department of Commerce. Transactions directly incident to the exportation or reexportation of such goods, such as the provision of cargo insurance for the transportation of the goods, are authorized by § 515.533. For additional information, see Note 1 to paragraph (a) of 31 CFR § 515.533.

Persons subject to U.S. jurisdiction, however, are prohibited from engaging in reinsurance arrangements where the underlying activity is not authorized by the CACR. For example, a person subject to U.S. jurisdiction would be prohibited from participating in a reinsurance arrangement that involved coverage for a foreign company that provides investment opportunities in Cuban state- owned businesses. 
 

Date Released
September 23, 2020