News & Analysis as of

Office of Foreign Assets Control (OFAC) Insurance Industry

Troutman Pepper Locke

Between a Claim and a Hard Place: OFAC Sanctions Preempt State Insurance Laws

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U.S. sanctions laws present complex conflicts with state insurance laws. While state laws govern the timely payment of claims and other insurance practices, U.S. sanctions administered by the U.S. Department of the Treasury’s...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2024

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You are reading the November 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -...more

Morgan Lewis

New OFAC FAQs Offer Guidance on Insurers’ OFAC Compliance Obligations

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The US Office of Foreign Assets Control recently amended its insurance-related FAQ and issued two new FAQs. This focus on insurance-related guidance comes at the same time as an enforcement action targeting an insurer that...more

Troutman Pepper Locke

OFAC Issues New and Amended FAQs ‎for the Insurance ‎Industry

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On November 13, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended several insurance-related Frequently Asked Questions (“FAQs”) (61, 62, 63, 64, 65, 68, 69, 102, 103, and 104) as...more

K2 Integrity

Implementation of the Russian Oil Price Cap and Key Compliance Considerations

K2 Integrity on

As the Russian invasion of Ukraine continues, so too does Russia’s isolation from the West. Member nations of the Group of Seven (G7)—the United States (U.S.), Canada, France, Germany, Italy, Japan, and the United Kingdom...more

Seward & Kissel LLP

OFAC Issues Determination and Guidance For Russian Oil Price Cap Policy Commencing Today

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As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance and October 31, 2022 follow-on FAQ clarifying the applicability of the impending price cap policy) the U.S. Department of the Treasury’s...more

Vinson & Elkins LLP

Key Questions About Aircraft In Russia

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Since February 24, 2022, Russia’s invasion of Ukraine has led to unimaginable human suffering, a growing refugee crisis and a rising death toll. The invasion sparked a global response as governments moved to sanction the...more

Cooley LLP

War and Office of Foreign Assets Control Exclusions: Insurance Policy Language Matters

Cooley LLP on

Nearly two weeks into the Russian invasion of Ukraine, numerous companies are focused on how the war might impact their business, including their insurance coverage. This advisory provides a high-level overview of two types...more

Husch Blackwell LLP

New York’s DFS Publishes A Cyber Insurance Risk Framework

Husch Blackwell LLP on

Keypoint: New York’s Division of Financial Services (DFS) now requires Property and Casualty Insurers writing cyber insurance to comply with the Division’s Cyber Insurance Risk Framework to manage their risk. In her...more

ArentFox Schiff

New York DFS Circular Letter No. 2 (2021): Cyber Risk Framework for Property & Casualty Insurers

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On February 4, 2021, the New York Department of Financial Services (DFS) issued Circular Letter No. 2 (2021) to all authorized property and casualty insurers in New York, outlining a “Cyber Risk Framework” that all authorized...more

American Conference Institute (ACI)

[Virtual Event] AML & OFAC for the Insurance Industry - January 21st, 8:45 am - 5:00 pm EST

ACI’s Virtual Forum on AML & OFAC Compliance for the Insurance Industry offers one day of key insights, strategic knowledge, and actionable solutions to ensure that your business avoids costly sanctions and ensures compliance...more

Morrison & Foerster LLP

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more

Cozen O'Connor

English Court Considers if U.S. Controlled Marine Insurers Must Pay Claim in Light of Sanctions

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Mamancochet Mining Limited v Aegis Managing Agency Limited and Others - In this important recent marine insurance case, London based but U.S. controlled insurers were ordered by an English court to pay a cargo insurance...more

A&O Shearman

Mere risk of exposure to sanctions insufficient for underwriters to avoid liability

A&O Shearman on

Underwriters could not rely on a sanction limitation and exclusion clause in an insurance policy, which referred to insurers’ “exposure” to sanctions, to avoid liability for a claim simply because there was a risk that the...more

Hogan Lovells

Iran sanctions: Snapback becomes reality

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The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more

Carlton Fields

Changes in Cuba May Impact the Insurance Industry

Carlton Fields on

While much remains to be determined, the recent easing of U.S. restrictions on travel to and trade with Cuba may bring opportunities for U.S. and global insurance companies. However, many questions and obstacles remain. This...more

Morgan Lewis

OFAC Cites Violations in Dealings with Specially Designated Nationals

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Insurance companies and financial institutions are targeted. On August 2, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a Finding of Violation against two different insurance...more

Troutman Pepper Locke

The Iran Sanctions Program: Is There Relief in Sight for Re/Insurers Under The Iran Nuclear Agreement?

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers complex and comprehensive trade and financial sanctions against the Government of Iran. The Iran sanctions prohibit virtually all...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2015

Welcome to the August 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange...more

Carlton Fields

New York-Based Marine Insurer Settles Potential U.S. Sanctions Violations

Carlton Fields on

As if to provide a not-too-subtle reminder to insurers of the applicability of U.S. trade sanctions to their businesses, the Treasury Department’s Office of Foreign Asset Control (OFAC) announced on August 6, that a New...more

Davis Wright Tremaine LLP

Insurers Take Notice: Don’t Become a Casualty of Trade Sanctions Violations!

The U.S. Department of Commerce’s Office of Foreign Assets Control (OFAC) announced that Navigators Insurance Company, which is headquartered in New York and specializes in marine insurance and related lines of business,...more

Morrison & Foerster LLP

Iran Sanctions: Change is Coming, But Risks and Uncertainties Remain

The Joint Comprehensive Plan of Action (“JCPOA”) that was signed on July 14, 2015 among Iran and the United States, Germany, UK, France, Russia and China (referred to as “P5+1” in the United States and “E3+3” in the EU) could...more

BakerHostetler

The Nuclear Deal With Iran: The Lifting of Sanctions and Implications for Business

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On July 14, 2015, after two years of sometimes intense negotiations, the United States, the United Kingdom, France, Germany, Russia, and China (known as the “P5+1” countries), along with the European Union, signed a Joint...more

King & Spalding

Finalized Iran Nuclear Deal Outlines Changes for U.S. and EU Sanctions

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On July 14, 2015, negotiators from Iran, the EU, and the P5+1 countries —China, France, Russia, the United Kingdom, the United States, and Germany—announced that they had reached a consensus on the final text of the Joint...more

Orrick, Herrington & Sutcliffe LLP

Policyholder Insider Quarterly

Five Lessons Health Care Companies Should Learn From Cyberattacks - The American health care industry is under attack by sophisticated hackers seeking access to electronic medical records. Since January, three health...more

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