Aon International Energy, Inc. OFAC Settlement: $36K

Aon Energy facilitated the placement of coverage and the payment of premiums for facultative retrocession reinsurance that reinsured construction risks associated with a petroleum project on Kharg Island in Iran, with the apparent violations occurring in October 2005. Aon Energy brokered and placed the facultative retrocession reinsurance on behalf of a European reinsurer with two European retrocessionaires. The combined premium for the two retrocession reinsurance placements was $62,883.

Aon Energy did not voluntarily disclose this matter to OFAC. OFAC viewed the apparent violations as part of a pattern of reckless, but not egregious, conduct by Aon Energy in connection with these policies. The settlement amount reflects OFAC's consideration of the General Factors: Aon Energy provides specialized insurance services resulting in transactions that were particularly harmful to the sanctions program; Aon Energy, under the direction of its parent, Aon, took several steps to strengthen its OFAC compliance program and its existing OFAC procedures after the apparent violations; Aon Energy had not been the subject of prior OFAC penalties or other OFAC administrative actions; and Aon Energy cooperated with OFAC and entered into a tolling agreement with OFAC, which was undertaken by Aon on behalf of Aon Energy.

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