Civil Enforcement Information - American International Group, Inc. (1st action)

Date issued: May. 08 2014

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TURBOFAC Commentary (477 words)

Notes:

1) For further factual information see Settlement Agreement - American International Group, Inc. (1st action).

2) Bases for liability:

The Canadian subsidiary of a U.S. company was subject to the CACR as a result of 515.329.

i) Compare insuring Cuban-related business risks to similar cases involving Iran (AON International, 2011). For the ITSR, this is characterizable as facilitation of the underlying transaction. Here, of the many ways such activity could be said to violate 515.201(b), the insurance policy "involves" property in which Cubans have an interest (i.e. the subject to the underlying transaction). It is not clear whether the insurance of "Cuban business risks" means policies directed at or otherwise particularly likely to cover those risks specifically,...