18 May 2022
On 17 March 2022 the UK Government published a General Trade Licence in part to clarify earlier amendments to the UK Russia (Sanctions) (EU Exit) Regulations (the “Regulation”). Specifically, the licence addresses the issue as to whether it is lawful under the Regulation for insurers and reinsurers domiciled or operating from the United Kingdom to provide insurance for vessels calling at Russian ports or transiting Russian territorial waters.
A copy of the General Trade Licence (the “Licence”) can be found here.
The Licence provides that where the underlying trade is lawful and in accordance with applicable sanctions, UK domiciled Clubs, or UK domiciled subsidiaries, branches and management companies of Clubs, may insure and handle cl18aims arising out of vessels engaged in a trade to and from Russia and / or transiting Russian waters provided that the Club notifies the UK Secretary of State of the name and address at which records are kept in relation to each use of the Licence. The contents of the records that the Club is required to keep are set out in Regulation 76 (General trade licences: records) and include:
This information must be held by the Club until the end of the calendar year in which the information is recorded plus a further period of four years.
From 17 March 2022, it is now necessary for the owners of vessels that have called in a Russian port or transited Russian territorial waters to notify their club of that call providing as far as possible the details required by Regulation 76. A failure to do so may invalidate the vessel’s P&I insurance cover and / or prevent the Club from covering a claim. Please note that this requirement applies to all insured vessels (including Russian domiciled and flagged vessels) and is not limited to Insureds domiciled in the UK or operating UK flagged vessels.
Insureds are therefore requested to provide within one month of a call to a Russian port or a transit of Russian waters the information requested together with a copy of the bill(s) of lading for the relevant voyage. The information should be submitted to firstname.lastname@example.org using the template spreadsheet format.
Trade involving Russia is now subject to significant legal restrictions. Insureds are reminded that cover is not available for trade that breaches applicable sanctions and are advised to conduct thorough due diligence on the parties, cargoes and trade involved before engaging in trade to, through or from Russia.
The North of England P&I Association Limited / North of England P&I DAC
Copyright © The North of England Protecting and Indemnity Association Limited, trading as Sunderland Marine. All Rights Reserved. Registered in England. No. 505456. Registered Office at 100 The Quayside, Newcastle upon Tyne, NE1 3DU. North is authorised by the UK’s Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.
Sunderland Marine’s business in the EEA is underwritten by North of England P&I Designated Activity Company, a wholly owned subsidiary of North incorporated in Ireland and regulated by the Central Bank of Ireland.
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