The US government has again expanded the scope of its Iranian extraterritorial sanctions program with the enactment of the Iran Freedom and Counter Proliferation Act of 2012 (the “IFCPA”). Among other things, the IFCPA provides for ISA type sanctions against non US insurers who conduct underwriting services or insurance or reinsurance activities relating to Iran. The measures are extremely broad and are designed to punish non US insurers who engage in the Iranian market. The new measures are effective July 1, 2013.
View full memo, "US Extraterritorial Sanctions Targeting Non-US Insurers for Iran-Related Activities"