Is payment of Iran-related insurance or reinsurance claims made on or after November 5, 2018 sanctionable if the claim arises from an incident that occurred prior to November 5, 2018?

OFAC's answer

Payment of Iran-related insurance or reinsurance claims arising from incidents that occurred prior to November 5, 2018 could create sanctions exposure for non-U.S. persons to the extent such payment involves a person designated in connection with Iran’s proliferation of WMD or support for international terrorism, or an Iranian person on the SDN List, other than a non-designated Iranian financial institution, or if the underlying activity involved such persons or was otherwise sanctionable at the time it occurred. U.S. persons continue to be generally prohibited under the ITSR from exporting goods, services, or technology directly or indirectly to Iran, including participating in the payment of claims to or for the benefit of Iran or any persons blocked under the ITSR, or for the transportation of Iranian-origin oil, unless exempt or specifically authorized by OFAC. In addition, after November 4, 2018, to the extent a claim payment involves a U.S.-owned or -controlled foreign entity, the payment of such claim would be prohibited and would require an authorization from OFAC prior to payment. See [FAQ 102](https://ofac.treasury.gov/faqs/102) and [FAQ 103](https://ofac.treasury.gov/faqs/103) for additional information relating to U.S. person involvement in global insurance policies and [FAQ 303](https://ofac.treasury.gov/faqs/303) and [FAQ 304](https://ofac.treasury.gov/faqs/304) for additional information on secondary sanctions, and exceptions to these sanctions, such as the humanitarian exception, relating to insurance, reinsurance, or underwriting activities relating to Iran.

Related programs

Related FAQs

• #102How can an insurer or reinsurer participate in worldwide insurance markets through global insurance policies if, by definition, coverage extends to potential risks in sanctioned countries?
• #103What if market circumstances of the relevant commercial setting do not permit the use of a U.S. sanctions-specific exclusionary clause?
• #303Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA's section 1246(a)(1)?
• #304Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?