Frequently Asked Questions

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 … devices to Iran or for the provision of humanitarian assistance to the people of Iran can be insured, reinsured, or… Read more

63. What should an insurer do if it discovers that a policyholder or a named beneficiary is added to OFAC's Specially Designated Nationals and Blocked Persons List (SDN List) or located in a jurisdiction subject to sanctions?

… 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 … sanctions… Read more

1200. If a non-sanctioned person files a claim with their insurance company for a loss caused by a blocked person, such as a designated terrorist organization, is the insurance company permitted to pay the claim?

… OFAC is aware that insurers at times receive claims from non-sanctioned persons in non-comprehensively sanctioned … List of Specially Designated Nationals and Blocked Persons (SDN List). For example, a U.S. insurance company may receive a claim request for death… Read more

303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA's section 1246(a)(1)?

… 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 … or marketing of petroleum or petroleum products from Iran).… Read more

64. If an insurance policy is held by the employer on behalf of its employees, is it permissible for an insurer to maintain the policy if it covers a blocked person on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List), since the insurer is transacting only with the employer and not with the blocked person?

… If an insurer has knowledge that a person covered under a group policy, for example a worker's compensation policy, is blocked pursuant to OFAC sanctions, the insurer’s coverage of that person pursuant to the worker's compensation policy is blocked. If… Read more

772. Are insurers that are persons subject to U.S. jurisdiction allowed to provide travel insurance to persons subject to U.S. jurisdiction engaged in authorized travel to Cuba?

… Are insurers that are persons subject to U.S. jurisdiction allowed to provide travel insurance to persons subject to U.S. jurisdiction engaged in authorized travel to Cuba? … Are insurers that are persons subject to U.S. jurisdiction allowed to… Read more

68. If a policyholder becomes a Specially Designated National (SDN) or blocked person after policy issuance, can the insurer notify the policyholder that the policy is now "blocked"?

… Yes. The insurer may notify the policyholder that the policy is blocked without obtaining a specific … becomes a Specially Designated National (SDN) or blocked person after policy issuance, can the insurer notify the policyholder that the policy is now "… Read more

778. Does a person subject to U.S. jurisdiction require an OFAC specific license to pay an insurance claim that arises from authorized activity in Cuba if the payment involves a Cuban national?

… Where the provision of insurance-related services is authorized by general license, either expressly or as a transaction … Does a person subject to U.S. jurisdiction require an OFAC specific license to pay an insurance claim that arises from authorized activity… Read more

643. Is payment of Iran-related insurance or reinsurance claims made on or after November 5, 2018 sanctionable if the claim arises from an incident that occurred prior to November 5, 2018?

… Payment of Iran-related insurance or reinsurance claims arising from incidents that occurred prior to November 5, 2018 … FAQ 102 and FAQ 103 for additional information relating to U.S. person involvement in global insurance policies and FAQ 303 and FAQ 304 for… Read more

1199. Can a claim be paid under a policy issued to a blocked individual or entity if the payment is to an innocent third-party (for example, the injured party in an automobile accident)?

… The insurance company should contact OFAC for additional guidance. OFAC will work with you on the … may weigh in favor of authorizing payments to innocent third parties. Ultimately, the insurance policy itself is a blocked contract, so all otherwise prohibited… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence