OFAC FAQ (Current) # 104 - Compliance for the Insurance Industry

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (291 words)

Notes:

1) OFAC acknowledges that the issue of travel insurance is ordinarily incident to travel (where travel is exempt).

2) While there are no Crimea embargo regulations to say so explicitly, OFAC's statement here presumably applies to the Crimea embargo as well, seeing as it was enacted under 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. This FAQ was issued/last updated subsequent to the issue of 13685.

3) The North Korean sanctions regulations also exempt transactions "ordinarily incident to travel" even though travel to North Korea has been effectively barred through non-sanctions-based means (i.e. special passport requirements).

4) FAQ amended on 11-13-24 to specify that “[t]he authority granted to the President by the International Emergency Economic Powers Act (IEEPA) does not include the authority to regulate or prohibit, directly or indirectly, transactions ordinarily incident to travel to or from any country,” such that regulations and EOs need not make any specific reference to the travel exemption for it to apply. See generally General Note on the Applicability of IEEPA/TWEA Exemptions in EOs and Sanctions Regulations not Specifically Mentioning Them.

5) FAQ amended to specify that “the issuance and provision of travel-related insurance coverage related to exempt travel,” i.e. it is not only in the context of “global travel insurance and worldwide travel assistance” that such insurance is exempt from regulation. (See Notable Examples Illustrating the Scope of the Travel Exemption).

6) FAQ amended on 11-13-24 to clarify that the provision of travel insurance coverage related to authorized travel to Cuba is a “travel-related service” (for purposes of 515.572 of the ).

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OFAC FAQ (Current) # 104 - Compliance for the Insurance Industry [PDF contains amended version(s)]

TURBOFAC Commentary (291 words)