According to OFAC, the Chicago-based insurer engaged in arrangements with other insurance companies in order to issue policies in Canada. However, OFAC found that neither the underwriting manager of the insurance company nor the insurer inquired regarding the travel destinations of the insured Canadian travelers, which, in some cases, involved travel to Cuba, in violation of the CACR.
Separately, OFAC alleged that the Swiss-based insurance company received $287,292 in premium payments pertaining to Cuba-related travel, and paid out $80,555 in claims under the coverages. OFAC noted that these apparent violations of the CACR appear to have resulted from a misunderstanding by the company - which at the time was a UK domiciled subsidiary of a U.S. firm - of the applicability of U.S. sanctions on Cuba to it.
To settle the potential civil liability, the Chicago-based insurer agreed to remit $170,535, while the Swiss-based insurance company agreed to pay $66,212. Both companies self-reported the apparent violations and otherwise cooperated with OFAC's investigation, and the agency found the cases to be non-egregious.
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