The New York's Department of Financial Services sent a letter, dated June 25, to 20 non-US reinsurers of any business transactions they had with entities linked to Iran. The letter was sent by Superintendent Benjamin Lawsky's office, after the New York regulator learned of three insurers issuing coverage for traders with Iran.

As the identities of the three banks were not known, the NY DFS sent the said letter to Swiss Re, Lloyds, Hannover Re, and17 others. The letter also asked for an explanation of the insurers' policies and procedures as well as all other lines of business that could be subject to law. This request was made to ensure compliance with existing laws such as the Iran Freedom and Counter-Proliferation Act of 2012 (IFCPA).

In addition, the foreign insurers were also asked about any business dealings they had with Glencore Xstrata PLC and Trafigura. This was after reports linked the two Swiss companies to Iran's nuclear program by supplying alumina to an Iranian firm.