OFAC Continues Focus on the Reinsurance Industry: General Re and Iran
Client Alert | 1 min read | 06.30.11
True to its word, OFAC has continued to announce settlements of what is reported to be a pipeline of dozens of cases in the insurance/reinsurance industry with yesterday's $59,130 settlement with General Reinsurance for reinsurance claim payments to Steamship Mutual Underwriting Association Limited for losses arising from National Iranian Tanker Company operations.
The settlement is significant for a number of reasons. While OFAC found the apparent violations "non-egregious" and Gen Re voluntarily disclosed the apparent violations, the payments "were pursuant to its facultative reinsurance obligation" and therefore this case represents another guide to OFAC's views on facultative arrangements. Perhaps most significantly, OFAC's announcement reflects a "risk-based" expectation for compliance; one of the mitigating factors cited is that "Gen Re subsequently . . . implemented training programs for personnel who have a high probability of encountering sanctioned transactions."
For questions about the Gen Re case or OFAC compliance obligations generally, please contact those listed on this alert.
Contacts
Insights
Client Alert | 2 min read | 07.01.25
DoD Establishes New DOGE Approval Process for ITC&MS and A&AS Contracts
On June 23, 2025, the DoD issued a memorandum, “Implementation of Department of Government Efficiency Cost Efficiency Initiative,” to establish a new DOGE approval process for unclassified IT consulting and management services (ITC&MS) contracts or task orders (TOs), and advisory and assistance services (A&AS) contracts or TOs. The memorandum establishes a formal approval process, which directs DOGE to review and provide input for certain contract requirement packages included in Defense Secretary Pete Hegseth’s May 27, 2025 directive, “Implementation of Executive Order 14222 – Department of Government Efficiency Cost Efficiency Initiative” (“Contract Guidance”).
Client Alert | 10 min read | 07.01.25
Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers
Client Alert | 8 min read | 06.30.25
Client Alert | 3 min read | 06.30.25
