OFAC Compliance in the Insurance Industry Checklist

Summary

This OFAC Compliance in the Insurance Industry Checklist will help insurers and their counsel know what to consider when making determinations about potential OFAC violations and help them understand what might trigger an OFAC violation. The potential for an OFAC violation exists for all lines of insurance, and, as of 2026, insurers should evaluate their sanctions controls in light of active U.S. sanctions programs, enforcement expectations, and sanctions-evasion typologies, including Russia-related measures, Iran-related restrictions, shadow-fleet and maritime sanctions-evasion concerns, and beneficial ownership and control issues. A proper response to a potential violation is crucial.