Civil Enforcement Information - American International Group, Inc. (2nd action)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (554 words)

Notes:

1) Read this enforcement action in conjunction with related maritime insurance cases, e.g. The American Steamship Owners Mutual Protection and Indemnity Association (2013), General Re (2011), HCC Insurance Holdings, Inc. (2011).

With regard to the violations arising out of "single shipment policies," it is fairly obvious from previous enforcement actions that providing insurance specifically for activities in which a U.S. person could not engage is itself a violation of various broad sanctions prohibitions.

What is somewhat novel about this case is the set of violations that were apparently for "premiums and claims for the insurance of maritime shipments of various goods and materials destined for, or that transited through, Iran, Sudan, or Cuba, and/or that involved a blocked person," but under global policies, as opposed to single-shipment policies.

While the mere collection of...

Welcome!

Welcome!

Civil Enforcement Information - American International Group, Inc. (2nd action)

TURBOFAC Commentary (554 words)