On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that escalating global conflicts are intensifying threats to the U.S. financial system. The letter highlights increased risk from destructive cyberattacks, sanctions evasion, and illicit activity involving virtual assets. NYDFS urges institutions to take immediate, proactive steps to strengthen operational resilience, ensure compliance, and protect the financial sector from geopolitical spillover.Read More NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

On September 20, 2018 the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued “OFAC Advisory to the Maritime Petroleum Shipping Community” to alert the shipping industry participants, including insurers, as to sanctions risks relating to petroleum shipments to or from Syria.  OFAC’s Syria Sanctions Program is
Read More OFAC Advisory to Maritime Shipping Industry

As we reported here in May, the Texas Legislature recently passed legislation (House Bill 1774, a copy of which can be found here) which amends Chapter 542 of the Texas Insurance Code—Texas’s general prompt pay statute for insurance claims.  Most of the new law’s provisions are aimed at addressing
Read More Uncertainty Surrounds New Texas Insurance Law: Divergent Views Emerge on the Impact of the Texas “Hail Storm Bill” on Hurricane Harvey Claims

Since the end of November 2013, the so-called P5 + 1 (the United States and its partners, China, France, the United Kingdom, Germany and Russia) have been negotiating with Iran regarding its nuclear program. The negotiations proceeded pursuant to a Joint Plan of Action (JPOA) providing temporary sanctions relief to

Read More JPOA Extended until July 7, 2015: “Temporary” Iran Sanctions Relief Continues until July 7, 2015

Coming on the heels of a recent NATO report that Russia is again massing troops near its border with Ukraine, the Office of Foreign Asset Control, part of the United States Treasury Department, announced the following new additions to the Specially Designated National List under its Ukraine-Related Sanctions Program: 
Read More The United States Treasury Department Names Seven Additional Ukrainian Separatists and Russian Nationals to the Specially Designated National List

The Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued new Ukraine-Related Sanctions Regulations, 31 CFR part 589, to implement Executive Order 13660 of March 6, 2014 (“Blocking Property of Certain Persons Contributing to the Situation in Ukraine”), Executive Order 13661 of March 17, 2014 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”), and Executive Order 13662 of March 20, 2014 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”).  These regulations were published as a final rule at 79 FR 26365 on May 8, 2014. 
Read More Official Ukraine-Related Sanctions Regulations Released

Last week, the Office of Foreign Asset Control of the U.S. Department of the Treasury (“Treasury”) added seven high-ranking Russian government officials and 17 Russian business entities to the Specially Designated National and Blocked Person List (“SDN List”) pursuant to authorization granted by Executive Order 13661, the details of which we discussed previously
Read More New Round of Sanctions Targets Russian Government Officials and Business Entities

The New York Department of Financial Services (“DFS”) has issued subpoenas to four insurers as part of an ongoing probe into violations of U.S. trade sanctions against Iran. 
Read More Four Insurers Subpoenaed as Part of Iranian Sanctions Investigation; Suspected of Insuring Foreign Commodities Trader Accused of Violating Trade Sanctions against Iran

On March 6, 2014, President Obama issued an Executive Order setting forth the foundation for imposing sanctions against any individual or entity responsible for or complicit in actions or policies that undermine democratic processes or institutions in Ukraine or threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine. 
Read More New Executive Order Regarding U.S. Sanctions against Certain Persons Contributing to the Situation in Ukraine

On November 24, Iran entered into a Joint Plan of Actionwith the United States, China, the Russian Federation, France, Germany, and the United Kingdom (the “E3/EU+3”), whereby in exchange halting to certain uranium enrichment activities and agreeing to be monitored by the International Atomic Energy Agency, the E3/EU+3 agreed to, among other things, suspend U.S. and E.U. sanctions on Iran’s petrochemical exports and associated services (“Joint Plan”). 
Read More Suspension of U.S. and E.U. Sanctions on Insurance Related to Iran’s Petrochemical Exports