Sanctions against Ukraine and Russia: Insurance/Reinsurance implications

The European Union (EU) and the United States (US) have now both taken targeted action against Russia (and certain former members of the Ukrainian government) to address the evolving situation in Ukraine. These measures do not yet impose broad-based country sanctions on Russia. As things stand, both the EU and US have designated a number of individuals for the purposes of asset freezes and travel bans. Currently the EU has targeted 32 persons and the US has targeted 20 persons. Further designations are likely. These designations are significant because of the positions these persons may have within the Russian government and commerce.  It will be important for (re)insurers and brokers to assess their business operations, interests and commercial activities in or connected to this region to determine whether they are affected. Hogan Lovells has reported on the developments relating to the imposition of sanctions in its newsflashes of 19 March 2014 and 21 March 2014. In addition, the UK has suspended all extant licences and licence applications for exports to the Russian Government and armed forces of military and dual use items.  It has also suspended licences for exports to third countries of equipment for incorporation in products to be exported to Russia where there is a risk that the end product will be used against Ukraine. Further, broader country or industry-based sanctions have been intimated by both the EU and US. Whilst these would be controversial, they will certainly be more damaging and could target Russia's energy, finance, banking and arms sectors. Should you have any specific questions relating to the impact of these sanctions on your insurance or reinsurance business you can contact the person with whom you usually deal, or Jamie Rogers in our London office.

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