SecProbe.io

March 28, 2018
Siddhartha Sankaran
Executive Vice President and Chief Financial Officer
AMERICAN INTERNATIONAL GROUP INC
175 Water Street
New York, New York 10038
Re:AMERICAN INTERNATIONAL GROUP INC
Form 10-K for the Year Ended December 31, 2017
Filed February 16, 2018
File No. 001-08787
Dear Mr. Sankaran:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2017
Item 1A Risk Factors
The USA Patriot Act, the Office of Foreign Assets Control and similar laws that apply to us may
expose us to significant penalties, page 26
1.In your letter to us dated January 15, 2015, you discussed possible contacts with Syria and
Sudan.  As you are aware, Syria and Sudan are designated by the State Department as
state sponsors of terrorism and are subject to U.S. economic sanctions and/or export
controls.  You do not provide disclosure about Syria or Sudan in your Form 10-K.  Please
describe to us the nature and extent of any past, current, and anticipated contacts with
Syria or Sudan since your 2015 letter, including contacts with their governments, whether
through subsidiaries, re-insurers, clients, brokers, affiliates, or other direct or indirect
arrangements.  Please also discuss the materiality of any contacts in quantitative terms and

 FirstName LastNameSiddhartha Sankaran
 Comapany NameAMERICAN INTERNATIONAL GROUP INC
 June 16, 2017 Page 2
 FirstName LastName
Siddhartha Sankaran
AMERICAN INTERNATIONAL GROUP INC
March 28, 2018
Page 2
in terms of qualitative factors that a reasonable investor would deem important in making
an investment decisions.  Tell us the approximate dollar amounts of any revenues, assets,
and liabilities associated with Syria or and Sudan for the last three fiscal years and the
subsequent interim period.  Address the potential impact of the investor sentiment
evidenced by divestment and similar initiatives that have been directed toward companies
that have operations associated with U.S.-designated state sponsors of terrorism.
Notes to Consolidated Financial Statements
13. Insurance Liabilities
Liability for Unpaid Losses and Loss Adjustment Expenses (Loss Reserves)
Loss Development Information
Supplemental Information , page 237
2.Please provide us an analysis supporting your presentation of the Adverse Development
Reinsurance Agreement as a separate column rather than reflecting its impact for each
year within each accident year within the development tables. Guidance in ASC 944-40-
50-4B indicates that amounts in the tables for incurred/paid claims and allocated claim
adjustment expenses should be presented on a net basis after risk mitigation through
reinsurance.  In addition, tell us the terms governing NICO’s payment obligations under
the agreement. In this regard, there does not appear to have been any payments to you
from NICO during 2017 based on information in the column "paid impact of Adverse
Development Reinsurance Agreement" within the tables titled "cumulative paid losses and
allocated loss adjustment expenses, net of reinsurance."
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at 202-551-3679 with
any questions.
Division of Corporation Finance
Office of Healthcare & Insurance