OFAC recognizes that U.S. insurers and reinsurers often compete in international markets where non-U.S. insurers are willing and able to issue global insurance policies without an exclusion that applies to U.S. sanctions, or where such clauses may be prohibited under local law. In cases where an exclusionary clause, as described in FAQ 102, is not commercially feasible, but the policy would involve the provision of coverage to a sanctioned person or jurisdiction, or prohibited activity, the insurer should apply to OFAC for a specific license prior to issuing the global insurance policy. In determining whether to issue a license, OFAC will review the facts and circumstances of each global insurance policy, including the market position of the applicant and the relevant risk frequency and risk severity, to assure that issuance of the policy will not undermine U.S. foreign policy goals. A separate license would typically be required for the insurer to pay claims that would be prohibited under U.S. sanctions arising under any authorized global insurance policy. For guidance on how to request and apply for a specific license, please see 31 CFR § 501.801 and the OFAC License Application page on OFAC's website.
Date Updated: November 13, 2024