Case No. IA-2016-334844-1
[***]
American Export Lines
13500 S. Figueroa St.
Los Angeles, CA 90061
Dear Mr. [***]:
This is in reply to the September 10, 2016 request by American Export Lines (the “Application”), seeking interpretative guidance from the Office of Foreign Assets Control (OFAC) on whether U.S. financial institutions who underwrite or are part of a payout related to an insurance policy underwritten by a U.S. or British surety related to the export of goods authorized under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR), can payout a U.S. person in U.S. dollars if there is a claim against the policy that has been underwritten.
In your Application, you indicate that your underwriter (a U.S. or British surety) is stating that although they will process insurance transactions for Iran shipments (exports...
1) The applicant is a U.S. person shipper that make an insurance claim related to the export of goods from the U.S. to Iran. The applicant’s “underwriter (a U.S. or British surety) [was] stating that although they will process insurance transactions for Iran shipments (exports from the U.S. to Iran) that are authorized by an OFAC general license or specific license, they cannot ensure that any financial institutions involved in their payouts will be able to payout on any claims in U.S. dollars,” so the U.S. person claimant sought guidance “on whether U.S. financial institutions who underwrite or are part of a payout related to an insurance policy underwritten by a U.S. or British surety related to the export of goods authorized under the Iranian Transactions and Sanctions Regulations…can payout a U.S. person in U.S. dollars if there is a claim against the policy that has...