American International Group OFAC Settlement: $279K

Last updated: July 20, 2026

American International Group, Inc. settled potential civil liability for 3,560 apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. part 515, agreeing to remit $279,038 to resolve conduct that occurred between January 1, 2006, and March 29, 2009.

Penalty Amount

$279,038.00

Enforcement Date

May 8, 2014

Rank in Top Penalties

#169

Case Details

Type:: Entity
Name:: American International Group, Inc.
Country:: 🇺🇸 United States
Industry:: Insurance
Address:: New York, New York
Penalty amount:: $279,038.00
Base civil monetary penalty:: $413,390.00
Egregious case:: No
Apparent violations:: 3560
Voluntary self disclosure:: Yes
Case:: Settlement
Violation period:: January 1, 2006 to March 29, 2009
Program:: Cuban Assets Control Regulations, 31 C.F.R. part 515
Enforcement date:: May 8, 2014

Nature of the Apparent Violations

Between January 2006 and March 2009, two AIG subsidiaries in Canada issued or renewed three types of property and casualty insurance policies that insured Cuban risks of a Canadian corporate entity for an estimated aggregate premium of $486,137.71. The policies involved Comprehensive General Liability, Director's and Officer's ("D&O") Excess Liability, and Pollution Legal Liability coverages. One of the AIG subsidiaries in Canada also maintained a D&O Liability insurance policy that insured certain directors and officers of three Cuban joint venture partners of a Canadian corporation between January 1, 2006, and October 4, 2006. The estimated total premium for D&O coverage during this time period was $55,578.08.

Separately, from March 17, 2006, through September 30, 2008, Travel Guard Canada — an AIG subsidiary in Canada — sold, renewed, or maintained in force 3,446 individual or annual multi-trip travel insurance policies in which the insured identified Cuba as the travel destination. The total premium collected for these policies was $337,973.25. During the coverage period of these 3,446 policies, and extending to December 31, 2008, Travel Guard Canada paid 103 claims for a total value of $96,910.47.

How OFAC Determined the Penalty

OFAC determined that AIG voluntarily self-disclosed the apparent violations and that the apparent violations constitute a non-egregious case. The total base penalty amount for the apparent violations was $413,390. The settlement amount of $279,038 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Aggravating Factors

AIG, including certain members of the institution's management, had actual knowledge of the conduct that led to the apparent violations
AIG's conduct resulted in harm to U.S. sanctions program objectives
The compliance programs of AIG's two Canadian subsidiaries were inadequate at the time of the apparent violations

Mitigating Factors

AIG has not received a penalty notice or Finding of Violation in the five years preceding the earliest date of the transactions giving rise to the apparent violations
AIG has taken appropriate remedial action in response to the apparent violations
AIG cooperated with OFAC's investigation by submitting a voluntary self-disclosure and executing a statute of limitations tolling agreement and multiple extensions of the agreement

Official Source Documents

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Archived on June 13, 2026

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