The U.S. Department of the Treasury’s Office of Foreign Asset Control (OFAC) administers numerous United States sanctions and restrictions programs and maintains records of current restrictions and sanctions under these programs. As announced in the Agent Updates Bulletin issued October 28, 2021, Citizens is prohibited from doing business with any individual or entity on an OFAC restrictions or sanctions list.

To conduct OFAC screenings, Citizens will require Social Security numbers/Federal Employer Identification Numbers (FEINs) on Personal and Commercial lines new business with an effective date of February 1, 2022, and later for:

• First named insureds
• Additional named insureds

Notes:

• OFAC screenings also will take place for additional interests, but Citizens is not requiring their Social Security numbers/FEINs.
• OFAC screenings will take place if any named insured or additional interest is added or updated.
• Citizens also will require date of birth for named insureds who are individuals.

This information also will ensure more accurate results when:

• Obtaining loss history reports
• Processing insurance claims
• Reporting unclaimed property to state government agencies

New Required Fields

For all new business with an effective date of February 1, 2022, or later, PolicyCenter® will have new required fields for:

• First named insureds
• Additional named insureds

Depending on whether the first named insured/additional named insured is an individual or an entity, note the required fields marked by an asterisk on the Policy Info screens shown below:

Figure 1: Policy Info screen for individuals who are first named insured

Figure 2: Policy Info screen for entities who are first named insured

If the individual or entity is on an OFAC restrictions or sanctions list, Citizens will block the corresponding account in accordance with OFAC requirements and will notify them of the blocked status.

Citizens soon will announce more information regarding privacy to applications and form changes.

Notes

Social Security numbers/FEINs are encrypted in our systems and only will be used for the above-mentioned reasons.

An updated Notice of Privacy Policy will be included in the Declarations packet effective February 1, 2022.

See Citizens’ Privacy Policy for more information about Citizens’ use of personal information.

Resources

• Financial Sanctions section of the U.S. Department of the Treasury website
• Agent Updates Bulletin: New Appointment and Renewal Requirement dated October 28, 2021