[FULL TEXT IN NATIVE PDF FILE]
FOREIGN ASSETS CONTROL REGULATIONS AND THE INSURANCE INDUSTRY
U.S. insurance carriers, responding to the foreign needs of clients, routinely offer international insurance to their domestic clients. U.S. insurers form alliances with foreign companies to gain footholds in countries where client bases are rapidly expanding. U.S. underwriters dramatically increase their involvement in lucrative international reinsurance markets. Everywhere you turn traditional barriers, as well as protections, are falling.
It is critical that the insurance industry gain a better understanding of the economic sanctions and embargo programs of the United States. The programs are a front line defense against foreign threats to our national safety, economy, and security. Libya, Sudan, and Cuba are all the focus of full-fledged trade embargoes, including the blocking of assets in U.S. jurisdiction. There are restrictions on imports from Burma and North Korea; new investments in...
1) This document was removed from OFAC's website at some point prior to 2011, presumably because many of the specific programs referred to have been repealed, and those still in existence have substantially changed form (i.e. Iran, North Korea). The CACR-related discussion is substantially out of date in light of general licenses pertaining to insurance contracts in which ordinary Cubans have an interest.
2) THE SCOPE OF AND PROHIBITIONS RELATED TO "BLOCKED CONTRACTS"
The guidance is notable in part for its identification of a range of insurance policy types such that, due to a blocked persons "interest" in the contract, the entire policy would be blocked. The following example is notable as the sort of "interest" that has not yet (from 2006 to 5/2019) been the subject of an enforcement action:
...