Steptoe’s Guy Soussan and Jack Hayes recently published an article in Insurance Day about the implications for the insurance, reinsurance, and brokerage industry under the Joint Comprehensive Plan of Action (JCPOA) related to Iran.  There are five key points:

  1. Virtually all EU insurance-related sanctions would be removed.
  2. Some, but not all, US insurance-related sanctions would be removed – most sanctions applicable to US person insurers, reinsurers, and brokers apparently will remain in place.
  3. Entities outside the US that are owned or controlled by US persons would be licensed to conduct (specified) Iran business, but the scope of business to be authorized is not specified under the JCPOA, nor has the US government published guidance on this point.
  4. Lifting of sanctions is not immediate (or guaranteed based on the political dynamics involving a skeptical US Congress).
  5. Even if sanctions are lifted, due diligence and dealing with global financial institutions will be challenging for industry given that some targeted sanctions will remain.

Read the full article at Insurance Day (subscription required).