The US government has again expanded the scope of its Iranian extraterritorial sanctions program with the enactment of the Iran Freedom and Counter-Proliferation Act of 2012 (the “IFCPA”). Among other things, the IFCPA provides for ISA-type sanctions against non-US insurers who conduct underwriting services or insurance or reinsurance activities relating to Iran. The measures are extremely broad and are designed to punish non-US insurers who engage in the Iranian market. The new measures are effective July 1, 2013.

The IFCPA is included at sections 1241 through 1267 of the National Defense Authorization Act for Fiscal Year 2013. Section 1246 of the IFCPA requires the imposition of five or more of the sanctions set forth in the Iran Sanctions Act (as amended) (the “ISA”) against non-US entities that provide underwriting services or insurance or reinsurance...