OFAC Issues Separate Findings of Violation to Health Insurance Policy Issuer and Administrator

OFAC issued Findings of Violation (FOV) to AXA Equitable Life Insurance Company (AXA) and Humana, Inc., the parent company of Kanawha Insurance Company (Kanawha), AXA’s Third Party Administrator (TPA) for the insurance policies at issue. According to the enforcement information (see here and here) released by OFAC, the FOVs stem from AXA’s issuance of two insurance policies to, and Kanawha’s provision of TPA services to, persons who were designated under the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. Part 598.