Insurance giant American International Group agreed to pay the Office of Foreign Assets Control about $149,000 to settle 555 “apparent violations” of OFAC sanctions against Iran, Sudan, and Cuba.
From 2007 to 2012, OFAC said Monday, New York-based AIG . . .
. . . engaged in a total of 555 transactions totaling approximately $396,530 in 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.
AIG’s OFAC compliance program included recommendations for when to use exclusionary clauses in the policies it issued, OFAC said. The clauses disclaim coverage or claims that could violate U.S. economic sanctions.
But some AIG policies didn’t have the exclusionary clauses for the sanctioned countries or blocked persons.
In policies that had exclusionary clauses, the clauses were sometimes “too narrow in their scope and application to be effective,” OFAC said.
That caused AIG to collect premiums and pay some claims for shipments to Iran, Sudan, and Cuba.
AIG has 65,000 employees in 130 countries.
OFAC — part of the U.S. Department of the Treasury — gave AIG credit for a clean sanctions compliance record during the prior five years, and for having in place a sanctions compliance program.
AIG self disclosed the apparent violations, took remedial action, and cooperated with OFAC’s investigation.
The Office of Foreign Assets Control’s June 26, 2017 Enforcement Information is here (pdf).
Richard L. Cassin is the publisher and editor of the FCPA Blog.