Enforcement Release: November 14, 2024
American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations
American Life Insurance Company (ALICO), a Delaware subsidiary of MetLife, Inc. that offers group and individual insurance globally, has agreed to pay $178,421 to settle its potential civil liability for apparent violations of OFAC sanctions on Iran. From February 23, 2022 to August 14, 2023, ALICO issued group medical and life insurance policies, collected premiums, and paid claims to several schools and entities located in the United Arab Emirates and owned or controlled by the Government of Iran. ALICO processed 2,331 premiums and claims under these policies totaling $446,077. The settlement amount reflects OFAC’s determination that ALICO’s apparent violations were non-egregious and voluntarily self-disclosed.
Description of the Apparent Violations
Insurance Policy for Entity Owned or Controlled by...
1) Dealing in Group Policies Issued to Blocked Persons – Exportation of Services to Iran
From a legal basis for violation standpoint, the violations at issue here are relatively straightforward, but the facts are unusual.
In each case, there was a group policy issued to an entity (the “policyholder”) that was owned or controlled by the Government of Iran (as defined in 560.304 of the ITSR), such that the entity itself was a blocked person. Presumably these policies covered a wide range of individuals (e.g. school faculty and other UAE-located employees unlikely to have been ordinarily resident in Iran), but they were issued to the GOI entities themselves, such that the group policy was a contract in which the GOI had an interest. OFAC says that...