When notifying a policyholder that their policy is "blocked" due to OFAC sanctions, may the insurer also instruct the policyholder not to send further premium payments or that the insurer will not accept additional premium payments under this account?

Question: When notifying a policyholder that their policy is "blocked" due to OFAC sanctions, may the insurer also instruct the policyholder not to send further premium payments or that the insurer will not accept additional premium payments under this account? Answer: The insurer may instruct the policyholder that in accordance with applicable U.S. laws and regulations administered by OFAC, the insurer must place any subsequent premium payments into a blocked account. For funds, such as unearned premium payments, that are blocked in addition to the policy, an insurer may notify the policyholder that it has blocked funds in accordance with OFAC's regulations. The insurer may identify to the policyholder the corresponding sanctions program pursuant to which the insured took action. Any individual or entity whose funds or other property have been blocked due to OFAC-administered sanctions may apply for the release of the funds or other property via the License Application page on OFAC's website. For additional questions about OFAC sanctions, you are encouraged to have the policyholder contact OFAC directly. Date Updated: November 13, 2024