OFAC sanctions pose increasing complexity to international business, says Karalee Morell of the Reinsurance Association of America.
The sanctions regime enforced by the Department of Treasury’s Office of Foreign Assets Control (OFAC), which bars or limits interaction with countries, entities or individuals that are determined to be sponsoring terrorism, is becoming increasingly complex.
Sanctions are currently being applied to various degrees with respect to Syria, Ukraine, Iran, Sudan and many others. These sanctions programmes continue to develop on an almost daily basis as international developments occur. Navigating the obligations and limitations imposed by US sanctions programmes adds to the growing complexity of the environment that exists for companies doing business internationally.
US trade controls—including sanctions—are far-reaching, complex, and aggressively enforced and can apply to companies not domiciled in the US but who do business in the US, have US citizens as employees and/or use US products. This can be particularly onerous in the insurance and reinsurance contexts, where contracts govern global businesses, and extend over long periods of time, and when claims take time to process even after the contract period expires.
OFAC sanctions, Karalee Morell, Reinsurance Association of America, opinion