OFAC Issues Two Findings of Violation for Alleged Violations of Foreign Narcotics Kingpin Sanctions Regulations

Sanctions OFAC

On August 2, OFAC issued Findings of Violation (here and here) to two insurance companies for alleged violations of the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598. The findings of violation relate to a non-U.S. insurance company that issued insurance policies to persons subsequently designated as SDNs. The insurance policies were serviced by a U.S. insurance company, which collected insurance premiums from the SDNs and remitted the premiums to the non-U.S. company.  Neither company identified the designations until a separate company assumed responsibilities for servicing the policies. OFAC asserted that as large and commercially sophisticated companies providing insurance products and services, they “failed to implement controls and measures to ensure [they] could identify, block and report insurance policies, premiums, or claims payments in which an OFAC sanctioned person(s) had an interest.”