EU/UK financial and trade sanctions for insurers
Produced in partnership with Marcus Bonnell, Charlotte Thompson and Dil-veer Kang of RPC
EU/UK financial and trade sanctions for insurers

The following Insurance & Reinsurance guidance note Produced in partnership with Marcus Bonnell, Charlotte Thompson and Dil-veer Kang of RPC provides comprehensive and up to date legal information covering:

  • EU/UK financial and trade sanctions for insurers
  • Financial sanctions
  • Nature of the sanctions
  • Trade sanctions
  • Financial Conduct Authority
  • Screening and due diligence

Insurers must negotiate a patchwork system of financial and trade sanctions. In the UK, the primary responsibility for administering the sanctions framework is taken by HM Treasury, acting through the Office of Financial Sanctions Implementation (OFSI). A number of other government departments also have involvement in the system of UK sanctions, including the Department for Business, Energy and Industrial Strategy.

The trade and financial sanctions regime incorporates decisions of the United Nations Security Council in addition to restrictions imposed by the EU. The sanctions are implemented in the UK either by a UK statutory instrument (SI) and/or an EC Regulation (the latter of which is directly applicable in the UK).

Financial sanctions

HM Treasury is responsible for the administration and implementation of the financial sanctions regime in the UK. The breadth and depth of the restrictions change regularly according to relations between sanctioned countries on the one hand and the UN, EU and UK on the other.

There are currently 22 different countries subject to financial sanctions under UK law. The sanctions in force vary quite dramatically from country to country as does the resultant danger posed to insurers wanting to write risk there. By way of example, the financial sanctions in place against the Republic of Guinea-Bissau are narrow (asset freezes are in place against 21 individuals) and concern a country