Update on the Ukraine situation and trade to Russia, Ukraine and Belarus
The sanctions programmes related to the Ukraine situation has under a short period of time expanded and become very complex.
We urge our clients to continuously assess the situation and evaluate whether sanctions may be applicable to their business and trade involving Ukraine, Russia and Belarus, and if so, whether a general license might be required, as the prohibitions on export and import to and from Russia has expanded.
We kindly remind that it is the client’s obligation to ensure sanctions compliance, including a thorough due diligence ensuring transparency on counterparties and confirming origin of cargo. Due to the complexity, we recommend clients to seek external legal advice under any uncertainty, as a failure to comply with the EU, UN, UK and the US sanctions legislation will have implications for the insurance cover.
In addition to sanctions exposure, we recommend clients to monitor flag state(s) information regarding the current situation, as well as to include other aspects in their assessments, such as potential practical problems that may arise with payments, the security situation in general rights of the crew.
For further information on the development, we recommend monitoring the below websites.
Please contact your underwriter where specific questions in regard to insurance cover may arise.
Finnish Ministry of Foreign Affairs
UK: The Russia (Sanctions) (EU Exit) Regulations 2019
Reuters Overview: https://graphics.reuters.com/UKRAINE-CRISIS/SANCTIONS/byvrjenzmve/index.html
Insurance and reinsurance: https://ec.europa.eu/info/sites/default/files/business_economy_euro/banking_and_finance/documents/faqs-sanctions-russia-insurance_en.pdf
Export related restrictions: https://trade.ec.europa.eu/doclib/docs/2022/march/tradoc_160081.pdf
Insurance Marine News: https://insurancemarinenews.com/insurance-marine-news/sanctions-against-russia-could-have-major-impact-on-shipping-insurance-reed-smith/
US Maritime Advisories: https://www.maritime.dot.gov/msci-advisories
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