If an existing policyholder or a named beneficiary is blocked by OFAC and the provision of insurance services is not authorized or exempt, then the insurer is required to block the policy or relevant portion of the policy (e.g., the individual's policy under a group health insurance plan), report such blocking to OFAC within 10 business days from the date the policy becomes blocked, place any future premium payments into a blocked interest-bearing account at a U.S. financial institution, and, if applicable, seek an OFAC specific license to make any payments under the policy. For guidance on how to request and apply for a specific license, please see 31 CFR § 501.801 and the License Application page on OFAC's website.
In the case of sanctions that prohibit the provision of services to a particular jurisdiction, in most cases insurers should cease providing coverage to the relevant policyholder or named beneficiary located within the jurisdiction or with respect to the particular jurisdiction unless authorized by OFAC or otherwise exempt. (For more information on travel-related insurance coverage, see FAQ 104.)
The insurance company may contact OFAC with specific questions related to the policy.
Date Updated: November 13, 2024