American Steamship Owners P&I OFAC Settlement: $348K

Last updated: July 20, 2026

The American Steamship Owners Mutual Protection and Indemnity Association, Inc. (the "American Club"), a non-profit international marine mutual insurance association of merchant ship owners and charterers, settled potential liability for 55 apparent violations of the Cuban Assets Control Regulations, the Sudanese Sanctions Regulations, and the Iranian Transactions Regulations by agreeing to remit $348,000 to the Office of Foreign Assets Control.

Penalty Amount

$348,000.00

Enforcement Date

May 9, 2013

Rank in Top Penalties

#162

Case Details

Type:: Entity
Name:: The American Steamship Owners Mutual Protection and Indemnity Association, Inc.
Country:: 🇺🇸 United States
Industry:: Insurance
Address:: New York
Penalty amount:: $348,000.00
Base civil monetary penalty:: $1,729,000.00
Egregious case:: No
Apparent violations:: 55
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: November 15, 2003 to March 13, 2007
Program:: Cuban Assets Control Regulations ("CACR"), 31 C.F.R. part 515Sudanese Sanctions Regulations ("SSR"), 31 C.F.R. part 538Iranian Transactions Regulations ("ITR"), 31 C.F.R. part 560
Enforcement date:: May 9, 2013

Nature of the Apparent Violations

The American Club processed three Protection and Indemnity ("P&I") insurance claims totaling approximately $40,584 between January 19, 2004, and June 28, 2006, involving Cuba in apparent violation of the CACR. The American Club processed 18 P&I insurance claims, issued six Letters of Undertaking/Guarantee ("LOU"), and issued one letter of indemnity as security or countersecurity for an LOU totaling approximately $685,774.26 between November 15, 2003, and March 13, 2007, involving Sudan in apparent violation of the SSR. The American Club processed 21 P&I insurance claims, one LOU, and issued five letters of indemnity as security or countersecurity for an LOU totaling $488,453.65 between January 27, 2004, and August 8, 2006, involving Iran in apparent violation of the ITR.

How OFAC Determined the Penalty

OFAC determined that the American Club did not voluntarily self-disclose the apparent violations, and that the case was non-egregious. The base penalty for the Cuba-related apparent violations was $61,000; for Sudan, $844,000; and for Iran, $824,000, for a total base penalty of $1,729,000. In determining the $348,000 settlement amount, OFAC considered that the American Club had actual knowledge or reason to know that some P&I claim activity and LOUs involved sanctioned countries, and that the American Club is a sophisticated commercial entity.

Mitigating Factors

The American Club's conduct does not appear to have been willful or reckless
The P&I claims and LOUs constituting the apparent violations may have been licensable at the time the transactions occurred
The size of operations, financial condition, and other relevant factors related to the individual characteristics of the American Club
The American Club had not received a penalty notice or Finding of Violation from OFAC in the five years preceding the date of the transactions giving rise to the apparent violations
The American Club took appropriate remedial action following the apparent violations
The American Club cooperated with OFAC, including by providing all information in a responsive, well-organized fashion, and by signing a tolling agreement and two extensions to that agreement

Official Source Documents

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View archived version View on ofac.treasury.gov

Archived on June 13, 2026

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