INSIGHT: One of the world’s biggest insurance firms has fallen foul of U.S. sanctions – here are the key lessons

By Sarah Beth Felix , Special Correspondent

ANOTHER Office of Foreign Assets Control (OFAC) penalty issued by U.S. Department of the Treasury.

While a small amount – only $178,421 – it is an overall reflection that if you have knowledge, you have a burden. The maximum penalty could have been $858 million! Yikes.

American Life Insurance Company, owned by MetLife, voluntarily self-disclosed their errors. Here are some things to learn from – pay attention to number one, then go back and read it again. And again. Because I’ve been harping on this for years.

1) Just because a name passes the screening DOES NOT MEAN it is not a prohibited transaction, person, or entity. We have country-level sanctions and not all of them are broad restrictions like North Korea.

2) Sanctions screening must move past the mindset of the first item – and it must be treated like a nuanced AML-ish alert.

A ‘trigger’ to look at something and keep following the data and information trail to see if it is truly restricted. Like this example, the schools were owned by the government of Iran, but were not listed on the restricted entities. And we have several countries that have these nuanced sanctions. Not just Iran. Put on your investigator hat.

3) Insurance companies should take note – your documentation most likely has some information buried that does not sit in a “screenable” 01 format.

4) Other screening features outside of sanctions can serve as a possible lead to a sanctions issue. For this example, their PEP screening noted the Iranian embassy, but the sanctions screening system did not. Again, put on that investigator’s mindset.

5) For any company that has an third-party responsible for customer-facing and customer-entry (*cough* fintechs, brokers,, third party admins) – your company’s approach to sanctions compliance (screening, methodology, doc requirements, frequency of screening, etc) MUST be consistent throughout the process, regardless of what the legal agreement says between the layers.

6) An interesting and often forgotten aspect that OFAC highlights, is the lack of an internal process for flagging applicants who have been rejected. Especially if your business has another way to onboard customers.

After addressing ~1,000 people over the last two and a half months on the road, there has only been one person who has answered yes when I ask – “Who has operationalized the Treasury’s Framework for sanctions compliance?”. One. Uno. Hop to it y’all. You don’t need a pricey consultant to get started on it.

ANNOUNCEMENT: Dates for fast-growing European Anti-Financial Crime Summit confirmed – Dublin, May 7

‘EUROPEAN Anti-Financial Crime Summit 2025′ (EAFCS 2025), hosted by AML Intelligence, is set to return to Dublin on May 7 next, it’s been confirmed.

EAFCS is a key platform for top executives from banks, financial institutions, tech companies, regulators, and policymakers to discuss the most pressing issues in anti-financial crime.

The summit, which has become one of the most significant events on the European calendar, offers attendees the chance to hear from high-profile speakers and network with influential decision-makers in the field.

Join 900 Delegates from across the globe. Registration is now open HERE. Early Bird Rates now available.