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ARTICLE · 07 NOVEMBER 2014

OFAC Settlement Extends Violations To "Support Service" Providers

Morgan Lewis
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OFAC stated that an insurance company and its affiliates violated OFAC regulations by providing insurance support services for policies that were issued to, or provided coverage for, persons designated on the OFAC Specially Designated Nationals list.

United StatesInternational Law
Margaret Gatti
Margaret Gatti
Louis Rothberg
Louis Rothberg

OFAC stated that an insurance company and its affiliates violated OFAC regulations by providing insurance support services for policies that were issued to, or provided coverage for, persons designated on the OFAC Specially Designated Nationals list.

On October 29, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a consent settlement that raises novel and important implications for support services providers in the securities, insurance, and financial industries. The respondents were an insurance company and its affiliates, which are Florida corporations that provide insurance support services, and the settlement was for an agreed upon civil penalty of $128,704. The settlement involved potential civil liability for 39 apparent violations of various OFAC regulations, for which the maximum fine could have been $9.75 million.

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