JCPOA Implementation FAQ D-7 - Insurance Measures

Date issued: Jan. 16 2016

TURBOFAC Commentary (179 words)

Notes:

1) OFAC acknowledges that the provision of travel insurance for travel to an embargoed country benefitting from an IEEPA-based travel exemption is ordinarily incident to travel (and permits the "servicing of such policies" is ordinarily incident to the provision of the insurance itself [see FAQ 104]). The insurance need not be issued in connection with a global policy, as is the case with the CACR. Note that because the CACR has no travel exemption, the provision of all insurance related to Cuba travel is handled through general licenses (see e.g. 515.580).

2) While there are no Crimea embargo regulations to say so explicitly, this presumably applies to the Crimea embargo as well, seeing as it was enacted under IEEPA and the source of the authorization for the issue of global travel insurance is that it is ordinarily incident to travel exempt from regulation under IEEPA.

The North Korean sanctions regulations also exempt transactions "ordinarily incident to travel" even though actual travel to North Korea by U.S. passport holders has been effectively barred through non-sanctions-based means.