OFAC FAQ (Current) # 64 - Compliance for the Insurance Industry [PDF contains amended version(s)]

Date issued: Nov. 13 2024

Last substantive commentary amendment:
Nov. 15 2024

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TURBOFAC Commentary (726 words)

Notes:

1) Consistent with FAQ # 63, this FAQ confirms that a group policy (“for example a worker's compensation policy”) is not blocked property in its entirety just because a blocked person is covered by the policy; instead, it is only that “portion of the policy” which is blocked. As discussed in the comments to FAQ # 64, this is an important determination clarifying that not every insurance policy in which a blocked person has some interest is blocked in its entirety when sanctions-implicating aspects of the contract can be segregated from others, and this has implications for other types of contracts as well. Refer generally to General Note on the Blocking of “Contracts” and the Determination of Persons Having an “Interest” in “Contracts.

2) Reason to Know

With respect to the following paragraph:

“under some group policies,...