In 2017, CalSTRS designated Swiss Re as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Swiss Re after reviewing the company’s business with Iran and internal controls to prevent sanction violations.
"Swiss Re Says Currently Assessing The Impact Of The Announced U.S. Withdrawal From Iran Deal On Our Business" (5/18/2018)
In 2017 the U.S. state of California listed Swiss Re as a company under review for reportedly providing insurance services related to Iran.
"New York's top financial regulator has expanded a probe into whether reinsurance companies have written policies on international trade with Iran, which could potentially violate new U.S. sanctions. In a letter posted to its website on Wednesday, the state's Department of Financial Services asked reinsurers to explain their dealings with entities and people that have ties to Iran. The department also asked reinsurers to explain procedures in place to ensure compliance with the Iran Freedom and Counter-Proliferation Act of 2012, which took effect on July 1. Twenty reinsurers are getting the letter, including Hannover Re, Lloyd's of London and Swiss Re, a person familiar with the matter said. Those reinsurers were among those contacted last month by the regulator, whose superintendent is Benjamin Lawsky, over their dealings involving Iran… The new law bans financial services companies that do business in the United States, such as insurers and reinsurers, from providing services to companies that trade with Iran. Such a ban can make it harder for shippers to transact with Iran, because they need insurance to protect against the risk of losses on big shipments." (Reuters, "NY Regulator Expands Probe Into Reinsurers' Iran Ties," 7/24/2013)
"Swiss Reinsurance Co. and Lloyd's of London, the world's oldest insurance market, are among companies being probed by a New York regulator about their compliance with an expanded Iran sanctions law. The state Department of Financial Services is asking the insurers about their procedures to avoid violations of the Iran Freedom and Counter-Proliferation Act of 2012, according to a letter from the department obtained by Bloomberg News... 'We believe a robust due diligence regime is required to ensure than an insurance company is fully advised of the risks it is taking,' the department said. 'Because an insurer may violate the IFCPA by engaging in conduct it should have known was improper, incautious due diligence could expose an insurer to the imposition of sanctions.' The regulator asked the companies for a copy of every policy issued to Glencore Xstrata Plc or Trafigura that will remain in force after today, according to the letter. The department cited news reports of 'a pattern of trades' made by Glencore and Trafigura with Iranian entities. At least one trade involved Glencore's shipment of alumina to the Iranian Aluminum Co. in exchange for processed aluminum." (Bloomberg, "Insurers Quizzed by N.Y. Regulator Lawsky on Iran Links," 7/1/2013)