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U.S. National Security Export Controls/FAC: Insurance Industry
State insurance statutes regulate an insurer's ability to withhold claim payments, cancel policies or to decline to enter into policies. In some cases, insurers must commit an ostensible violation of state insurance regulations to comply with OFAC regulations. Does OFAC have a position as to whether OFAC regulations preempt state insurance regulations in this context?
At what point must an insurer check to determine whether an applicant for a policy is an SDN?
What should an insurer do if it discovers that a policyholder is or becomes an SDN--cancel the policy, void the policy ab initio, non-renew the policy, refuse to pay claims under the policy? Should the claim be paid under a policy issued to an SDN if the payment is to an innocent third-party (for example, the injured party in an automobile accident)?
A workers' compensation policy is with the employer, not the employee. Is it permissible for an insurer to maintain a workers compensation policy that would cover a person on the SDN List, since the insurer is not transacting business with the SDN, but only with his/her employer?
How frequently is an insurer expected to scrub its databases for OFAC compliance?
Is it sufficient if my company screens life insurance policies only prior to policy issuance?
If my policyholder, who is a U.S. person, requests a change of beneficiaries and designates a cousin living in Cuba as a beneficiary under the life insurance policy, what shall I do?
If my screening efforts uncover a policyholder who became an SDN after policy issuance, can I notify the policyholder that the policy is
In my letter to the policyholder whose policy is “blocked,” may I also instruct the policyholder not to send any more premium or that we will not accept additional premium under this account?
How can an insurer participate in worldwide insurance markets through global insurance policies if, by definition, coverage extends to potential countries?
What if the commercial setting and/or market circumstances of a global insurance policy does not permit the use of an OFAC exclusion such as the one noted above?
Can an insurer offer global travel insurance and worldwide travel assistance without violating U.S. sanctions?
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