Insurance industry participants, including underwriters, brokers, and agents, are responsible for compliance with OFAC sanctions throughout the lifecycle of their involvement with an insurance policy or other product or service.
If a U.S. insurer receives an application for a policy from a person whose property and interests in property are blocked, such as a person on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), OFAC sanctions prohibit the insurer from issuing the policy, unless authorized or exempt, because doing so would provide a service (i.e., coverage) to the blocked person. If the blocked person sends a deposit to the insurer along with the application, the deposit must be blocked and reported to OFAC within 10 business days, unless authorized or exempt. If an insurer receives an application from a party on one of OFAC's other sanctions lists, please review the relevant prohibitions carefully before taking any action. For information on specific prohibitions, authorizations, or exemptions under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website.
Date Updated: November 13, 2024