OFAC FINDING OF VIOLATION AGAINST HUMANA, INC., AND A SUBSIDIARY

Humana, Inc., and its subsidiary, Kanawha Insurance Company, have been found to have violated the Foreign Narcotics Kingpin Regulations [Kingpin Act]. Three individuals, placed on the OFAC SDN List, in 2009, were serviced by Kanawha, as a Third Party Administrator, for an undisclosed company.

Neither Humana nor Kanawha screened the named insureds of the health insurance policies it serviced for the third party, and improperly accepted 34 premium payments, without identifying and blocking them. The subsidiary, Kanawha had a compliance program that did not include procedures for screening the names of policyholders of policies that it administered, but for which it did not assume any financial responsibility; This should be considered a fatal flaw. In compliance, it recommended that we check everybody that we deal with: clients, customers, vendors, payees, and any other category where we could have liability for sanctions violations, if we have meaningful contact in the business sphere.