The US Department of Treasury fined a New York-based insurer nearly $300 000 for 48 apparent violations of sanctions against North Korea, Iran, Sudan and Cuba. The insurers despite knowing they were dealing with OFAC-sanctioned countries provided coverage to North Korean vessels and were involved in incidents involving the other countries. The policies were issued by personnel in the UK who were probably unclear about OFAC regulations.
The possibility of incurring these penalties is the reason why an exclusion for indemnifying anyone who is sanctioned is now in all reinsurance policies. Companies need a comprehensive sanctions compliance program.