American Life Insurance Company (ALICO)

American Life Insurance Company (ALICO), a Delaware-based subsidiary of MetLife, Inc., has agreed to pay $178,421 to settle its potential civil liability for violating U.S. sanctions on Iran. Between February 2022 and August 2023, ALICO issued group medical and life insurance policies and processed 2,331 premiums and claims totaling $446,077 for UAE-based schools and entities owned or controlled by the Government of Iran (GOI). Despite compliance screenings, ALICO failed to recognize that these policyholders were GOI-controlled, allowing them to purchase coverage and receive claim payouts.

One of the violations involved an insurance application initially rejected due to the entity’s ownership by the Iranian embassy. However, the same sales agent resubmitted the application through an alternative channel, using an altered trade license that removed references to the Iranian government. This allowed the policy to be approved without triggering additional compliance scrutiny. ALICO also accepted a $78,143 cash payment after an earlier attempt to pay with a check from Bank Melli Iran was rejected—overlooking that Bank Melli is a blocked entity under U.S. sanctions. Additionally, ALICO issued coverage to another school in the UAE that had "Islamic Republic of Iran" on its documents, yet the connection to the GOI was not flagged.

OFAC determined that ALICO’s violations were non-egregious but highlighted significant failures in due diligence and compliance controls.