Case No. SY-2017-346682-1

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TURBOFAC Commentary (562 words)

Notes:

1) Notwithstanding the substantial redactions in the first paragraph, this guidance letter provides a few noteworthy insights into various aspects of OFAC practice. We first note that the transactions at issue involved AIG paying a reinsurance claim with respect to an underlying insurance policy “provided to a Syrian national no longer residing in Syria”. It is likely, given the reference to foreign affiliates and branches, that a non-U.S. person issued the initial policy and it was reinsured by AIG, but this is unclear.

2) Insurance Claims of Persons “Not Currently” in Syria

It is also not clear from the letter whether the Syrian national was “ordinarily resident” in Syria at the time the underlying policy was issued (in that case presumably by a non-U.S. person), but note that OFAC concludes that “it appears that all contemplated transactions would involve...

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Case No. SY-2017-346682-1

TURBOFAC Commentary (562 words)