EU/UK financial and trade sanctions for insurers
Produced in partnership with Daniel Martin of HFW

The following Insurance & Reinsurance practice note produced in partnership with Daniel Martin of HFW provides comprehensive and up to date legal information covering:

  • EU/UK financial and trade sanctions for insurers
  • Effect of Brexit on UK sanctions implementation
  • Financial sanctions
  • Nature of the sanctions
  • Explicit prohibition on insurance and reinsurance
  • Prohibition on the provision of funds, economic resources and financial services
  • Trade sanctions
  • Financial Conduct Authority
  • Screening and due diligence
  • Governance
  • More...

EU/UK financial and trade sanctions for insurers

Insurers must negotiate a patchwork system of financial and trade sanctions. In the UK, the primary responsibility for administering the financial sanctions framework is taken by HM Treasury, acting through the Office of Financial Sanctions Implementation (OFSI). The Department for International Trade's Export Control Joint Unit administers trade sanctions, and the Department for Transport administers shipping related sanctions. The Foreign, Commonwealth and Development Office is responsible for setting overall UK sanctions policy.

The trade and financial sanctions regime incorporates decisions of the United Nations Security Council, as well as unilateral UK sanctions and measures equivalent in effect to financial sanctions, such as those imposed under the Anti-terrorism, Crime and Security Act 2001. The UK's sanctions framework is established by the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). Individual sanctions regimes are then implemented through statutory instruments made under the authority of SAMLA 2018.

Effect of Brexit on UK sanctions implementation

Since the end of the Brexit implementation period, the UK has become responsible for its own sanctions policy.

Initially, EU sanctions were retained in UK domestic law by the operation of section 3(1) of the European Union (Withdrawal) Act 2018. However, the EC Regulations were immediately repealed on the coming into force of the various statutory instruments made under SAMLA 2018 that establish the UK's sanctions regimes. While broadly aligned with

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