Customer advisory: Impact of sanctions on insurance policies Executive summary Due to the heightened regulatory environment surrounding trade and economic sanctions compliance, insurers have reminded their insureds to perform proper due diligence before entering into any contract. They have also announced widened sanctions exclusion clauses — clauses which will allow them to suspend or terminateRead more
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Throughout our series of 12 articles, we have explored the sanctions compliance landscape, with each of the articles focusing on a particular aspect. The importance and many intricacies of sanctions compliance are not ones to overlook. The dynamic nature of sanctions means there are frequent updates ranging from newly sanctioned entities or changes to newRead more
The dynamic nature of sanctions means there are frequent changes and updates ranging from newly sanctioned entities to or changes to embargoes and tariffs put in place. Accordingly, many new and evolving sanctions evasion attempts are ongoing. In our 5 ‘red flags’ article, we discussed a handful of the many tactics used to attempt toRead more
Global awareness of the sanctions compliance landscape has increased. We regularly read and observe countless news reports, political discussions and enforcement actions that have become the talking point throughout the start of 2022. This tool of political foreign policy has been implemented en masse, in an attempt to stop aggressive actions and limit the devastatingRead more
Sanctions vary situationally, geographically and politically. As a result, there are different types of sanctions imposed, including but not limited to environmental, diplomatic, military and economic. Sanctions and other restrictions can be imposed through some of the following measures: Tariffs – a government-imposed tax on the import of goods and services from a country. ThisRead more
Penalties for a sanction breach can range from monetary to deferred prosecution agreements (DPA) and can be as severe as criminal prosecution. Substantial financial penalties can and have been issued and publicly disclosed which can have severe reputational impact. Enforcement penalties issued by OFAC in 2019 alone hit a record high of $1.3 billion. TheRead more
1. Raise awareness in your organisation The first step to putting in place a robust compliance programme is to ensure that everyone in the organisation is aware of the importance of sanctions compliance and their obligations in this regard. This policy should document how and when to perform risk assessments, transaction monitoring and screenings. 2.Read more
The maritime sanctions landscape is constantly evolving. Geopolitical changes, diplomatically-led coercive actions and even global pandemics have impacted the sanctions landscape, and to varying extents could continue to do so. A greater priority The Refinitiv 2021 risk report results concluded that 40% of organisations had said that COVID-19 made sanctions screening a greater priority. ThisRead more
The complexity of the maritime sanctions landscape is not one to underestimate. Careful consideration needs to be taken by the entire maritime industry. With the trading world merchant fleet projected to reach 79,282 vessels by the end of 2025, it is important that industry players are aware of the tactics used to evade sanctions (includingRead more
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