OFAC FAQ (Current) # 303 - Sanctions Relating to Insurance, Reinsurance, or Underwriting (relating to IFCA)

Date issued: Nov. 27 2019

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TURBOFAC Commentary (1290 words)


1) This FAQ was initially issued in 2013, and amended in 2019. The original FAQ read as follows:

303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA's section 1246(a)(1)?
A number of insurance activities are subject to sanctions under IFCA, including providing insurance, reinsurance, or underwriting services to persons on the SDN List sanctioned for activities with respect to Iran. [06-03-13]

That was a fairly non-substantive characterization of Sec. 1246(a)(1) of IFCA, which as of 2019 has still not yet been implemented in regulations.

The FAQ was amended in 2019, in connection with the issuance of FAQ 805, FAQ 806 and FAQ 807. The FAQ is more specific as to the scope of activities that are actually sanctionable pursuant to the insurance-related secondary sanctions provision...