On May 9, 2013, the Office of Foreign Asset Control (“OFAC”) announced a settlement with the American Steamship Owners Mutual Protection and Indemnity Association, Inc. (the “American Club”) under the OFAC sanction programs against Cuba, Sudan and Iran.  The American Club is a non-profit international marine mutual insurance association of merchant ship owners and charterers with its principal offices in New York.  OFAC reported that, while the American Club did not voluntarily self-disclose any violations, there were mitigating factors present and any violations were non-egregious.  For a copy of the official OFAC enforcement action, click here.  The American Club agreed to pay $384,000 to settle potential liability under OFAC sanctions.