The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $466,200 settlement with Privilege Underwriters Reciprocal Exchange (PURE). PURE agreed to settle its potential civil liability for 39 apparent violations of OFAC's Ukraine-/Russia-Related sanctions.
Based in White Plains, New York, PURE primarily offers insurance policies and coverages for luxury homes, automobiles, art collections, jewelry, and watercraft
Between May 2018 and July 2020, PURE engaged in transactions related to four insurance policies involving a blocked Panama-based company owned by Specially Designated National Viktor Vekselberg (Vekselberg). PURE’s underwriters failed to upload the shareholder information from the corporate disclosure statement into PURE’s underwriting systems where corporate ownership information is stored.
The settlement amount reflects OFAC's determination that PURE's apparent violations were not voluntarily self-disclosed and were non-egregious.
Among aggravating factors, even after relevant sanctions expanded and OFAC published its guidance on the 50 Percent Rule in 2014, PURE took no subsequent due diligence or other measures to identify this gap until it received a government inquiry in 2022. This resulted in PURE’s providing services to a blocked person for more than two years.
Mitigating factors included PURE undertaking remedial measures, including screening its entire customer base through two third-party vendor tools, and requiring its underwriting department to upload all potential or existing customers’ corporate disclosure statements into PURE’s system and escalate any applications involving a non-U.S. entity for review and approval by PURE’s management and compliance staff.
Further, PURE cooperated with OFAC’s investigation by providing information and timely responses to OFAC. PURE also signed a tolling agreement.
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