General Reinsurance Corporation OFAC Settlement: $59.1K

General Reinsurance Corporation made two reinsurance claim payments to the Steamship Mutual Underwriting Association Limited ("Steamship Mutual") for losses arising from vessel operations of the National Iranian Tanker Company. The payments occurred in July and August 2005 and were made pursuant to Gen Re's facultative reinsurance obligation to Steamship Mutual for the coverage period June 16, 1998, to February 20, 2002. The combined amount of the two reinsurance claim payments was $309,740.65.

Gen Re voluntarily disclosed this matter to OFAC, and the transactions do not constitute an egregious case. The base penalty for the apparent violations was $131,424. The settlement amount of $59,130 reflects OFAC's consideration of the following: Gen Re is the largest U.S. reinsurer and one of the largest reinsurers in the world; the apparent violations resulted from activities of certain claims personnel, including a Vice President for Claims, that were contrary to Gen Re sanctions compliance policies and procedures; Gen Re subsequently installed enhanced sanctions compliance software and implemented training programs for personnel who have a high probability of encountering sanctioned transactions; Gen Re substantially cooperated with OFAC by signing a tolling agreement and promptly responding to all requests for information; and Gen Re has not previously been the subject of OFAC penalties or other OFAC administrative actions.

The apparent violations resulted from activities of certain claims personnel, including a Vice President for Claims, that were contrary to Gen Re's existing sanctions compliance policies and procedures. In response, Gen Re installed enhanced sanctions compliance software and implemented training programs for personnel who have a high probability of encountering sanctioned transactions.

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