Generali Global Assistance, Inc. OFAC Settlement: $5.9M

Last updated: July 20, 2026

Generali Global Assistance, Inc. (GGA), a New York-incorporated travel assistance services company that provides travel and claims services on behalf of clients that offer global medical expense and travel insurance policies, settled with OFAC for $5,864,860 to resolve 2,593 apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515. GGA intentionally referred Cuba-related payments to its Canadian affiliate, thereby avoiding processing reimbursement payments directly to Cuban parties and to travelers while they were located in Cuba, and subsequently reimbursed its Canadian affiliate for those payments.

Penalty Amount

$5,864,860.00

Enforcement Date

October 1, 2020

Rank in Top Penalties

#51

Case Details

Type:: Entity
Name:: Generali Global Assistance, Inc.
Country:: 🇺🇸 United States
Industry:: Insurance
Address:: New York
Penalty amount:: $5,864,860.00
Base civil monetary penalty:: $84,272,500.00
Max civil monetary penalty:: $168,545,000.00
Egregious case:: Yes
Apparent violations:: 2593
Voluntary self disclosure:: Yes
Case:: Settlement
Violation period:: June 26, 2010 to January 15, 2015
Program:: Cuban Assets Control Regulations ("CACR"), 31 C.F.R. Part 515
Enforcement date:: October 1, 2020

Nature of the Apparent Violations

Between at least June 26, 2010, and January 15, 2015, GGA served as a travel services provider on behalf of two Canadian insurers that offered medical expense, travel insurance, and emergency travel insurance policies for non-U.S. Canadian subscribers who travelled to Cuba. GGA dealt in blocked property in which Cuba or a Cuban national had an interest by (i) providing prohibited post-travel claim reimbursements directly to Canadian travelers who travelled to Cuba, and (ii) providing for the indirect payment of claims to Cuban service providers through a Canadian affiliate.

For requests for payments intended for Cuban service providers, GGA intentionally referred those requests to a Canadian affiliate. GGA would then reimburse the Canadian affiliate after it had paid the Cuban service providers. GGA codified this referral process in its procedures manual, which provided instructions to GGA employees on how to service Canadian travelers' policies. GGA drafted this policy in 2010 and updated it in 2013, and it was approved by its Chief Executive Officer.

GGA had a sanctions compliance policy in place at the time of the Apparent Violations that required screening against OFAC's SDN List but failed to require screening for countries and regions subject to OFAC prohibitions. In servicing these policies, GGA processed 2,593 transactions with a value of $285,760 in apparent violation of § 515.201 of the CACR.

How OFAC Determined the Penalty

The statutory maximum civil monetary penalty applicable in this matter is $168,545,000. OFAC determined that GGA voluntarily self-disclosed the Apparent Violations and that the Apparent Violations constitute an egregious case. Accordingly, under OFAC's Economic Sanctions Enforcement Guidelines, the base civil monetary penalty amount applicable in this matter is $84,272,500. The settlement amount of $5,864,860 reflects OFAC's consideration of the General Factors under the Enforcement Guidelines.

Aggravating Factors

GGA appears to have demonstrated recklessness when it intentionally avoided making direct payments to Cuban service providers and instead formalized a referral process to make reimbursement payments to those providers indirectly through a Canadian affiliate when it knew that it would be illegal to make those payments directly; and by providing prohibited post-travel claim reimbursements directly to unauthorized Canadian subscribers who travelled to Cuba
GGA was aware of the conduct at issue because its policy requiring that claims reimbursement for providers located in Cuba be referred to GGA's Canadian affiliate was codified in GGA's customer service procedures and was approved by its Chief Executive Officer
GGA is part of a large and sophisticated global organization that provides travel services to insurers and other corporate clients worldwide

Mitigating Factors

With respect to harm caused to the CACR sanctions objectives, Cuba sanctions regulations were later amended to authorize some of GGA's problematic conduct and the total transaction value of the Apparent Violations was relatively low
OFAC has not issued any prior penalties, findings of violations, or cautionary, warning, or evaluative letters, or any other administrative actions (including settlements), in the five years preceding the earliest date of the transactions giving rise to the Apparent Violations
GGA took remedial action in response to the Apparent Violations, including by enhancing its existing OFAC compliance policies and procedures, establishing a formal structure for compliance personnel, and conducting a new sanctions training for all GGA employees
GGA cooperated with OFAC's investigation by voluntarily self-disclosing the conduct and signing a tolling agreement and multiple extensions to the agreement
GGA has confirmed that it has terminated the conduct that led to the Apparent Violations and has undertaken the following measures as part of its compliance commitments to minimize the risk of recurrence of similar conduct in the future: GGA commits to ensuring that its senior management, including senior leadership, executives, or the board of directors, are committed to supporting GGA's OFAC compliance program; GGA has designed and implemented written policies and procedures outlining its sanctions compliance plan and commits to enforcing the policies and procedures through internal or external audits; GGA commits to ensuring that its OFAC-related training program provides adequate information and instruction to employees and, as appropriate, stakeholders (for example, clients, suppliers, business partners, and counterparties) in order to support its sanctions compliance efforts

Compliance Takeaways

This enforcement action highlights the importance of ensuring that sanctions compliance policies and procedures address both direct and indirect sanctions compliance risks, and in particular, highlights the risks of implementing a procedure to process, indirectly, transactions whose direct processing would be prohibited by U.S. sanctions.

GGA's compliance policy required screening against OFAC's SDN List but failed to require screening for countries and regions subject to OFAC prohibitions, a gap that allowed the conduct to continue across thousands of transactions over several years.

Official Source Documents

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Archived on June 13, 2026

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