pi_circular Compliance & regulationGeopolitical risk Skuld
Circular issued by International Group clubs General Trade Licence dated 17 March 2022 – Reporting of vessel calls to Russia and transiting Russian territorial waters 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 claims 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: (a) a description of the act; (b) a description of any goods, technology, services or funds to which the act relates; (c) the date of the act or the dates between which the act took place; (d) the quantity of any goods or funds to which the act relates; (e) [the Insurer's] name and address; (f) the name and address of any consignee of goods to which the act relates or any recipient of technology, services or funds to which the act relates; (g) in so far as it is known to [the Insurer's], the name and address of the end-user of the goods, technology, services or funds to which the act relates; (h) if different from [the Insurer's], the name and address of the supplier of any goods to which the
Reporting of vessel calls to Russia and transiting Russian territorial waters
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