The question (No 303):
Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under section 1246(a)(1)?
A number of insurance activities are subject to sanctions under IFCA, including providing insurance, reinsurance, or underwriting services to persons on the SDN List sanctioned for activities with respect to Iran. [06-03-13]
The question (No 304):
Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?
Yes. IFCA includes the following exceptions to insuring, reinsuring, or underwriting sanctioned activities.a. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of humanitarian assistance to the people of Iran can be insured, reinsured, or underwritten.b. A person that provides insurance, reinsurance, or underwriting services to sanctioned activity, if a determination is made by the Department of the Treasury or the Department of State, as appropriate, that the person has established and enforced official policies, procedures, and controls to ensure that the person does not underwrite or enter into a contract to provide insurance or reinsurance for activities targeted under section 1246 of IFCA. The Department of the Treasury or the Department of State, as appropriate, will make this determination on a case by case basis as part of an investigation or enforcement action by the relevant Department. [06-03-13]
Categories: Guidance IFCA Iranian Sanctions OFAC Updates Sanctions Regulations
Leave a Reply