A number of insurance activities are subject to sanctions under IFCA, including knowingly providing insurance, reinsurance, or underwriting services to or for Iranian persons on the SDN List to or for any person designated in connection with Iran’s support for international terrorism or WMD proliferation, or for activities with respect to Iran for which sanctions have been imposed (e.g., knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran). However, the provision of insurance, reinsurance, or underwriting services to non-Iranian persons on the SDN List is generally not sanctionable under section 1246(a)(1) of IFCA if the provision of insurance, reinsurance or underwriting services is not to or for an Iranian person on the SDN List, to or for any person designated in connection with Iran’s support for international terrorism or WMD proliferation, or for any activity with respect to Iran for which sanctions have been imposed.
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