On 6 August, OFAC announced that the US-based Navigators Insurance Company (Navigators) had agreed to pay $271,815 to settle civil liability for apparent violations of multiple sanctions programs. From May 2008 to April 2011, according to OFAC, Navigators issued global protection and indemnity (P&I) insurance policies covering North Korean-flagged vessels, and also covered vessels that operated in Iran, Sudan and Cuba, some of which resulted in the payment of claims for activities in those countries. The transactions were voluntarily selfdisclosed, and OFAC considered the case to be non-egregious.

OFAC calculated the base penalty for 48 apparent violations at $755,042. For insurance of the North Korean flag vessels, OFAC calculated the base penalty by reference to the full amount of the premium collected plus the full amount of all claims paid. For the apparent violations involving Iran, Sudan and Cuba, OFAC’s base penalty calculation was based solely on the amount of the claims paid, and did not include an amount representing the pro rata portion of the premium attributable to coverage in the embargoed countries.