McGriff, Seibels & Williams OFAC Settlement: $122.4K

McGriff violated the ITR through the unlicensed design, revision, and placement, with foreign insurers, of six commercial multiple peril (CMP) insurance policies that insured the risks of a submersible oil rig in Iranian waters. The policy periods ran from May 1, 2004, to April 31, 2005. The combined premiums received by the foreign insurers for the six CMP insurance placements totaled $453,364.

McGriff voluntarily disclosed the matter to OFAC, and the alleged violations constituted a non-egregious case. The settlement amount of $122,408 reflects OFAC's consideration of the following: the insurance services provided by McGriff, which were highly specialized and involved the Iranian petroleum industry, were particularly harmful to the objectives of the sanctions program; the apparent violations resulted from the actions of a senior employee outside the knowledge of McGriff's senior management; McGriff strengthened its OFAC compliance program in response to the apparent violations; McGriff had not been the subject of prior OFAC penalties or other OFAC administrative actions; and McGriff cooperated with OFAC in the investigation, including entering into two tolling agreements.

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