Partner Kenneth Nunnenkamp and associate Eli Rymland-Kelly co-authored a Law360 Expert Analysis article reviewing recent amended and expanded insurance-related FAQs from the Department of the Treasury’s Office of Foreign Assets Control, or OFAC.
As the authors note, the FAQs provide more concrete guidance on insurers’ compliance obligations and dealings with sanctioned persons but do not address many of the issues that have arisen under the Russia sanctions program. The article also provides key takeaways for insurers seeking guidance on navigating compliance obligations.