NEW “IRAN THREAT REDUCTION ACT” IMPLICATES INSURANCE INDUSTRY

On August 10, 2012, President Obama signed The Iran Threat Reduction and Syria Human Rights Act (H.R. 1905) into law. Among other provisions, the Act contains provisions of particular import to the insurance industry, including bans on insuring or reinsuring: (1) vessels transporting oil from Iran if the insurer should have known that the vessel would be used for this purpose; (2) vessels transporting goods that could be used towards the proliferation of terrorism or weapons of mass destruction; (3) the National Iranian Oil Company or the National Iranian Tanker Company; and (4) barter transactions involving Iranian oil sales. Among other “safe harbour” provisions, the insurer may defend against violations of the Act (with the exception of (2) above), if it conducted due diligence in establishing and enforcing procedures to avoid violating the Act.

This post written by Michael Wolgin.

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