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Monday, October 22, 2012

It's Finally Here!!

The last I heard about my Iranian birth certificate was that my father's cousin in Iran had gone to the office in Tehran to inquire what happened to it (it's been over a year since I first applied with my old papers that were no longer legal). He found out that it had been sitting there waiting for a bribe. How were we supposed to know?! If you really want a bribe, at least let us know that we need to bribe you! I'm not sure what happened next (certainly no money left my pocket), but last week, we got a FedEx notice that something was en route to my father's address (note: nowhere on my application did I ever include my father's address, but this has happened before: where the Iranian government has gone above my head to make a point that my father is my keeper). We had the FedEx shipment diverted. So... yesterday, I got a thin envelope in the mail...




It's here!!! It's finally here!!!!! I have an official Iranian birth certificate (note: even though I was born in Seattle, WA, every child of a parent born in Iran gets this identity paper).

But here's the bummer part: This is just the first step. Now, I have to get my passport....

Yep. This isn't easy. Yes, it is maddening. Will my uncle who killed my grandmother even be alive by the time I get to Iran?? Will the place where she was buried be forever forgotten? Will the U.S. be at war with Iran by the time I am able to buy a ticket?

Meanwhile... we received this email at work from our Compliance department:

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Colleagues,

[The Company] is committed to conducting its business with integrity and we take our legal compliance obligations with the utmost seriousness. As you all know from the daily front page press reports, the US and UK are actively using economic sanctions to deter Iran’s nuclear weapons program. The Obama administration has been tightening sanctions, most recently in August, and [The Company] is now fully subject to all US sanctions for compliance purposes. The political situation in Iran is highly unstable as a result of the sanctions impact. A major goal of these sanction programs is to deprive Iran’s economy of insurance support from the international marine insurance market so they cannot export goods, including oil.  All of this makes for a very dangerous political situation and it requires that we all be extra vigilant in ensuring that [The Company] fully complies with our obligations under the sanction laws.

Please take a moment this week to refresh your understanding of [The Company's] financial crime policy and, most notably, our Economic Sanctions Policy contained in Appendix A.

Most importantly, if you become aware of any underwriting or claims transaction that involves Iran in any way, however remotely, please immediately advise the Legal/Compliance team. The rules are very complex and change frequently, so please do not attempt to make your own conclusions or contractual interpretations and do not rely on a broker’s representations that the sanctions do not apply if you learn that Iran is involved in the transaction in any way. Consult with our internal compliance experts!

More detailed procedures were rolled out in London last week for the [The Company's] underwriting teams and more detailed procedures will be rolled out this week for the US teams. Our biggest protection is the use of sanctions clauses that contain explicit references to US sanctions and diligent inquiries by our underwriters and our claim professionals.  If you have any questions about these procedures, please consult Legal/Compliance.

Thanks for your continued cooperation and vigilance.

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The cousin who was able to get my certificate moved through bureaucracy has also reported that groceries are difficult to buy in Tehran now. The effect of the sanctions has been devastating to my extended family who still live there. I highly doubt that the higher ups in government feel the effects at all, so when I get messages like this from my company, I feel a little ill.

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