Civil Enforcement Information - Allianz Global Risks US Insurance Company

Date issued: Dec. 09 2019

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (3179 words)

Consolidated Comment on the Allianz Global Risks US Insurance Company and Chubb Limited Enforcement Actions (in the comments to comments to Allianz Global Risks US Insurance Company (2019))

1) BACKGROUND

As was the case with the three June 13, 2019 enforcement actions related to the provision of Cuba-related travel services, OFAC appears to have announced the Chubb Limited (Chubb) and Allianz Global Risks US Insurance Company (Allianz) cases on the same day in light of the two serving as substantive "companion cases." We address the issues common and unique to the cases below.

2) JURISDICTION OVER THE FOREIGN ENTITIES AT ISSUE

In both cases, the way in which OFAC asserted jurisdiction over the entities at issue was slightly irregular.

In Allianz, the violating entity subject to the CACR was a foreign branch of...