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ENFORCEMENT INFORMATION FOR April 26, 2011
HCC Insurance Holdings, Inc. Settles Iranian Transactions Regulations Allegations: HCC Insurance Holdings, Inc., Houston, TX ("HCC Holdings"), has paid $38,448 to settle allegations of violations of the Iranian Transactions Regulations, 31 C.F.R. part 560 (the "ITR"), which were promulgated pursuant to, inter alia, the International Emergency Economic Powers Act and are administered by the Office of Foreign Assets Control ("OFAC").
OFAC alleged that Houston Casualty Company, Houston, TX, ("HCC"), HCC Holdings’ wholly-owned insurance subsidiary, violated §§ 560.206 and 560.208 of the ITR when it participated in a specialty aviation insurance policy that covered commercial flight operations in Iran during the period April 2005 – April 2006. Specifically, HCC participated in the hull portion of a aircraft hull and liability insurance placement by a foreign insurance broker that insured a foreign-owned commercial airline that leased aircraft to an air...
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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...