With reference to the UK Russia (Sanctions) (EU Exit) Regulations, the UK Government published a General Trade Licence on 17 March 2022 to clarify whether insurers and reinsurers domiciled or operating from the United Kingdom are lawfully able to provide insurance for vessels calling at Russian ports or transiting Russian territorial waters.
According to the Licence, on the basis that 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 Clubs notify 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 Clubs are required to keep are set out in Regulation 76 (General trade licences: records) and include the below, and must be held by the Club(s) until the end of the calendar year in which the information is recorded plus a further period of four years.
(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 act relates.
Members are therefore requested to send within [one month] of a call to a Russian port or a transit of Russian waters the information requested on the attached spreadsheet here, together with a copy of the bill(s) of lading for the relevant voyage to their Club. For further information, we suggest that you kindly refer to each Club’s website.
On a final note, all International Group Clubs have issued similar circulars whilst Steamship Mutual, has additional requests relating to trading with Belarus.