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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.

Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....