Privilege Underwriters Reciprocal Exchange — $466,200 OFAC penalty
OFAC published a $466,200 civil penalty against Privilege Underwriters Reciprocal Exchange on 12/21/2023. It is the #140 largest action in OFAC’s 1,052-entry enforcement chart and #12 of the 16 actions published that year.
What OFAC said
Sanctions Regulations Privilege Underwriters Reciprocal Exchange (PURE), an insurance organization based in White Plains, New York, that primarily offers insurance policies and coverages for luxury homes, automobiles, art collections, jewelry, and watercraft, has agreed to pay $466,200 to settle its potential civil liability for 39 apparent violations of OFAC's Ukraine-/Russia-Related sanctions.
Quoted verbatim from OFAC’s enforcement release — read the original.
The record
| Entity, as published by OFAC | Privilege Underwriters Reciprocal Exchange |
|---|---|
| Penalty / settlement amount | $466,200 |
| Date published by OFAC | 12/21/2023 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #140 of 1,052 |
| Rank within 2023 | #12 of 16 |
| Share of 2023 penalty total | 0.0% |
| Apparent violations cited | 39 |
| Statutory maximum penalty | $13,906,581 |
| Base penalty | $666,000 |
| Voluntarily self-disclosed | No |
| OFAC egregiousness determination | Non-egregious |
| Conduct period cited | May 2018 - July 2020 |
| Sanctions programs named in the release | Russia, Ukraine/Crimea |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $13,906,581. The settled amount of $466,200 is 3.4% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20231221_privilege_underwriters.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2023 actions
- Godfrey Phillips India Limited — $332,500
- Construction Specialties Inc. — $660,954
- DaVinci Payments — $206,213
- Uphold HQ Inc. — $72,230.32
- Emigrant Bank — $31,867.90
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