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Navigators Insurance Company, an insurance company that specializes in marine insurance and related lines of business, professional liability insurance, and commercial umbrella and primary and excess casualty businesses, settled its potential civil liability for 48 apparent violations of the Foreign Assets Control Regulations, Executive Order 13466, the North Korea Sanctions Regulations, the Iranian Transactions and Sanctions Regulations, the Sudanese Sanctions Regulations, and the Cuban Assets Control Regulations by agreeing to remit $271,815. The apparent violations arose from Navigators and its London, U.K. branch issuing global protection and indemnity (P&I) insurance policies that provided coverage to North Korean-flagged vessels and covered incidents that occurred in or involved Iran, Sudan, or Cuba — some of which led to the payment of claims. OFAC determined that Navigators voluntarily self-disclosed the apparent violations and that the apparent violations constitute a non-egregious case.
Penalty Amount
$271,815.00
Enforcement Date
August 6, 2015
Rank in Top Penalties
#172
Between May 8, 2008 and April 1, 2011, Navigators and its London, U.K. branch ("Navigators U.K.") issued global protection and indemnity ("P&I") insurance policies that provided coverage to North Korean-flagged vessels and covered incidents that occurred in or involved Iran, Sudan, or Cuba, some of which led to the payment of claims. Navigators did not have a formal OFAC compliance program in place at the time, and personnel within Navigators U.K. misinterpreted the applicability of OFAC sanctions regulations.
Between May 8, 2008 and February 18, 2011, Navigators provided insurance coverage to North Korean-flagged vessels under 24 P&I insurance policies and collected $1,142,237 in premium payments. Between February 23, 2009 and October 11, 2010, Navigators paid seven claims totaling $12,236 under these policies. Between March 16, 2009 and May 11, 2010, Navigators provided insurance coverage and processed 11 claims payments totaling $72,962 that involved Iran. Between April 28, 2009 and February 17, 2010, Navigators provided insurance coverage and processed five claims payments totaling $260,912 that involved Sudan. On April 1, 2011, Navigators made a claim payment of $21,736 in which a Cuban national had an interest.
Navigators voluntarily self-disclosed the apparent violations to OFAC, and OFAC determined the apparent violations constitute a non-egregious case. The base penalty amounts by program were: $577,237 for the North Korea-related policies and claims; $36,481 for the Iran-related claims; $130,456 for the Sudan-related claims; and $10,868 for the Cuba-related claim. The total base penalty for all 48 apparent violations was $755,042. The settlement amount of $271,815 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.
Navigators did not have a formal OFAC compliance program in place at the time it engaged in these apparent violations, and personnel within Navigators U.K. misinterpreted the applicability of OFAC sanctions regulations. In response, Navigators formed and implemented a comprehensive OFAC compliance program, which OFAC credited as appropriate remedial action.
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Archived on June 13, 2026
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