Civil Enforcement Information - HCC Insurance Holdings, Inc.

Date issued: Apr. 26 2011

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TURBOFAC Commentary (502 words)

Notes:

1) Within the class of enforcement actions dealing with the commercial insurance and reinsurance sector, the HCC Insurance Holdings case is particularly notable insofar as the penalty did not arise out of either i) a dealing in/placement of a policy directly related to Iran-specific risks, or otherwise ii) the payment of a claim arising out of an Iran-specific incident. (Compare with e.g. Aon International Energy, Inc. (2011) and McGriff, Seibels & Williams of Texas, Inc. (2011), dealing with insurance for Iran-specific projects, and Civil Enforcement Information - Gen Re (2011), dealing with a claim arising out of an Iran-related incident.

Instead, HCC was fined for participating in the insurance of a "foreign-owned commercial airline that leased aircraft to an air charter company that operated in Iran," in the context of what was presumably a policy for the entirety of...