AXA Group

In a correspondance with the SEC, AXA disclosed details regarding their investments in Iran.

“There are three non-US subsidiaries of the AXA Group provide insurance coverage to local subsidiaries or branches of entities known by AXA to be controlled by the government of Iran:  AXA UK has entered into insurance relationships with the UK operations of four state-controlled Iranian banks (three advisory relationships and one UK group pension relationship.  AXA Corporate Solutions, a French AXA subsidiary, has underwritten marine and aviation insurance policies for six companies based in Iran.  AXA Spain holds a 10% co-insurance participation in a marine insurance cover for an Iranian ship (AXA Spain took this 10% co-insurance participation under an insurance program covering the fleet of a Spanish fishing company which subsequently sold one of its boats –with its insurance cover- to an Iranian company.  The German branch of an AXA Assistance French subsidiary provides reinsurance coverage for 16 Iranian insurance companies. These reinsurance programs cover compulsory travel insurance for Iranian citizens entering the “Schengen area” (which consists of the European Union states where the free movement of persons is established). (CORRESP for AXA, 12/8/2009)  (https://www.sec.gov/Archives/edgar/data/898427/000095015709000953/filename1.htm','AXA',''))

Numerous subsidiaries provide insurance to Iran. (https://www.sec.gov/Archives/edgar/data/87347/000156459018000821/slb-10k_20171231.htm)

"Zurich Insurance Group AG (ZURN) is among companies being questioned by New York’s insurance regulator in a widening probe into compliance with an Iran sanctions law, according to a person familiar with the matter. The state Department of Financial Services is asking insurers to explain their policies and procedures to avoid violations of the Iran Freedom and Counter-Proliferation Act of 2012, according to the person. The act took effect July 1. ‘The resulting sanctions could jeopardize the ability of any involved insurer to conduct business in the United States,’ the department said in a letter to the insurers obtained by Bloomberg News. ‘Recently, the Department learned that several companies have insured trades made with Iran.’ The regulator, led by Superintendent Benjamin Lawsky, contacted a group of insurers in June about compliance with the law. That group included Swiss Reinsurance Co. (SREN) and Lloyd’s of London. Besides Zurich, other companies contacted in the newest letter are American International Overseas Ltd., AXA Global Risks, and St. Paul Reinsurance Co. Ltd." (Bloomberg, Zurich Among Insurers Said to Be Probed in Expanded N.Y. Inquiry, 7/24/13) (http://www.bloomberg.com/news/2013-07-24/zurich-among-insurers-said-to-be-probed-in-expanded-n-y-inquiry.html)

Has suspended any new marine insurance contracts with Iran; had insured shipping and shipments for Iran following the nuclear agreement. (Carolyn Cohn, Jonathan Saul, "U.S. sanctions seen barring IT platform of insurer Lloyd's for Iran trade," Reuters, July 13, 2018.) (https://www.reuters.com/article/us-iran-sanctions-insurance/u-s-sanctions-seen-barring-it-platform-of-insurer-lloyds-for-iran-trade-idUSKBN1K31TX)

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