The Next Targets Of The U.S. Sanctions Office

Earlier this year, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) penalized Navigator’s Insurance about $275,000 – not a lot compared to the big fines OFAC has leveled against some banks, but a significant development nonetheless, says Gibson Dunn attorney Adam Smith. Banks have largely “de-risked,” and this action indicates OFAC is now looking beyond banks to other kinds of businesses that also can be regarded as “foundational players in global commerce.” Insurance companies definitely qualify, and this is an industry “ripe for increased scrutiny and significant further enforcement action.”