Allianz settles with OFAC for $170,535

Allianz Global Risks US Insurance Company (“AGR US”) is a Chicago-based property casualty insurer and a wholly owned subsidiary of Allianz SE (“Allianz”), a German financial services provider organized under the laws of the European Union and Germany. AGR US operates AGR Canada (“AGR Canada”) as a Canadian branch office in Toronto, Canada. AGR US has agreed to remit $170,535 to settle its potential civil liability for 6,474 apparent violations of the Cuban Assets Control Regulations. OFAC determined that AGR US voluntarily self-disclosed
the apparent violations and that these apparent violations constitute a non-egregious case. The total base penalty amount for the apparent violations was $270,690.90.

Between August 20, 2010 and January 15, 2015, AGR Canada fronted travel insurance policies that included occasional coverage relating to Canadian residents’ travel to Cuba. “Fronting” insurance business involves an arrangement between two or more insurance companies to allow a company to issue a policy in a jurisdiction where it is not licensed. The insurance policies fronted by AGR Canada consisted of two types of insurance policies sold to Canadian citizens and residents covered by Canadian health plans: first, insurance coverage for an individual trip that would be in effect for 30 days for the specific trip (e.g., a single trip to Cuba), and second, insurance coverage that would be in effect for a full year and provide coverage for every trip taken during that time (e.g. covering multiple trips to several countries, including one or more trips to Cuba). The travel insurance policies covered reimbursement for eligible emergency medical expenses while out of country and non-refundable expenses resulting from trip cancellation, delay, or interruption due to specified categories of events.

A Canadian underwriting manager operating separately from AGR Canada underwrote, marketed, and serviced the insurance policies. Neither the underwriting manager nor AGR Canada collected information regarding the travel destination upon policy issuance. A travel destination was only disclosed to the underwriting manager in instances where emergency medical assistance was required, a claim was submitted, or a coverage inquiry was received disclosing the destination. AGR Canada received only a quarterly summary premium and claims information. Travel destination information was not included in that summary.