Background Explanation for AIMU U.S. Economic and Trade Sanctions Clause
The Forms and Clauses Committee recommends for all lines of business (cargo, hull and liability) the AIMU U.S. Economic and Trade Sanctions Clause. Approved for use by the Management Committee in July, 2003.
The Department of Treasury's instructions to the Insurance Industry under their guidelines reads:
"Could potential losses involve property located in, goods originating from or destined for, or persons or commercial activity in target countries? Again, decline the business or structure the policy to exclude risks within the geographical limits of embargoed countries and losses related to prohibited business involving those countries. Make sure your foreign associates fully understand the restrictions under which you, as a U.S. person, must operate. U.S. underwriters should communicate their sanctions constraints to the foreign brokers with whom they regularly deal."
OFAC will not offer an opinion regarding specific policy language, their enforcement guidelines do indicate that penalties will be lower for those who make good faith attempts to avoid violations!