Violating trade sanctions

BusinessInsurance.com reported on June 30 that General Re had been fined for violating trade sanctions against Iran as a result of its participation in Steamship Mutual's excess coverage from 1998-2001. In 2005, General Re paid its share of two claims incurred by National Iranian Tanker Co. totalling $310,000. The fine was said to be $59,130, and OFAC announced that "the transactions do not constitute an egregious case." You can read the press release at http://www.treasury.gov/resource-center/sanctions/CivPen/Documents/06292011.pdf.


General Re reportedly turned itself in to the Office of Foreign Assets Control ("OFAC"), blamed the violations on "certain claims personnel", installed "enhanced sanctions compliance software", and implemented training programs for their claims people.  Blaming the claims people seems unfair. Cliff Burns, who writes Export law Blog, points out that "OFAC guidance to the insurance industry makes clear that the issuance of the reinsurance to Steamship for its NITC policy would itself have violated OFAC rules without regard to whether any claims were actually made or paid to Steamship." However, the statute of limitations had run on the issuance of the policy itself. 


I was working in P&I when that contract was written in 1998, and I remember how hard it was to get people to take sanctions seriously back then.  The world has certainly changed. Steamship Mutual declined to renew the Iranian fleet this year, and no other Group Club would pick them up.

King Lear

Gwen and I saw King Lear with Derek Jacobi last night at BAM, and it was thrilling. His Lear was vivid, human, and prey to so many emotions. He strutted when he prompted his daughters to say how much they loved him; he was incredulous when Cordelia wouldn't follow suit; he was childishly happy to be free of kingship and then petulant when Goneril chided him about his retinue; he was rash when he left Regan's home for the moor; he lost his mind by degrees; he gradually woke to the peril he was in; he walked on carrying Cordelia and whispered, "I killed the knave who was a-hanging thee." He made all of that wonderful poetry serve the character. Some of the most famous lines came out like throwaways, because this Lear was not a philosopher; he was a vain king who had lost everything.

Goneril and Regan were stylish, and surprisingly modern, in slim black dresses (while the men were running around with swords), and distinct characters. Goneril in particular was quite sympathetic toward the beginning. Her complaints about Lear's retinue came out as the reasonable concerns of a woman whose houseguests were becoming far too much trouble. Regan was less aggressive at first, but picked up strength as she learned from her sister. Although Kent and others saw the two women as evil from the start, and Edmund is shown eavesdropping on their conversation and learning to be evil at the end of the first act, this production showed them growing more evil under Edmund's influence as time went on. They become violent monsters, and no one was sorry when their deaths were announced.

Gloucester, Edmund, Edgar and Kent were all well-cast. Kent's disguise was convincing, and Edgar was almost unrecognizable as Poor Tom. Edmund was handsome, athletic, but unsure enough to be persuasively baffled by the women's attention. 

I wish Jerry Zimler could have seen this production. I hope he would have liked it; the production tried hard to make up for the play's dramatic flaws. I know it would have held his attention and that he would have had a lot to say about it.