In response to country-wide turmoil and civil unrest and growing reports of deadly attacks by the Libyan government upon protesters, on February 25, 2011, President Barack Obama by Executive Order imposed broad economic sanctions against Muammar Qadhafi and his sons, senior officials of the Libyan government, persons involved in human rights abuses in Libya, persons providing financial or other support to Colonel Qadhafi, his family, the Libyan government or those violating human rights, persons owned or controlled by or acting on behalf of any of such persons and the families of any of such persons (“Blocked Libyan Person(s)”). Click here for a copy of the President’s Executive Order.

The sanctions imposed require United States persons, which include U.S. companies and their overseas branches, to freeze assets without notice to Blocked Libyan Persons. As a result, payments of claims or benefits by U.S. persons under insurance or reinsurance contracts to Blocked Libyan Person are prohibited. Entities controlled by the Libyan government are likely to be considered Blocked Libyan Persons and investments by Libyan sovereign wealth funds or government controlled entities in U.S. businesses are assets that would be frozen.

The Office of Foreign Assets Control of the U.S. Department of Treasury (“OFAC”) will administer the new Libyan sanctions. OFAC is in the process of developing guidance regarding and regulations implementing the Libyan sanctions. Click here to visit OFAC’s website page relating to Libyan sanctions.