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Economic Sanctions and Insurance

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Crowell & Moring’s international economic sanctions team has developed a unique niche serving as advisors to insurers and reinsurers on compliance with U.S., E.U. and U.K. sanctions legislation. With sanctions experts in Washington, London and Brussels, including lawyers with significant expertise in the insurance, banking and maritime sectors, we are able to provide fast, practical and insightful advice to help our clients navigate the complex multi-jurisdictional global sanctions regimes and to mitigate risk.

With over 20 years of experience advising clients in the insurance and maritime sectors, our team understands the insurance industry and, in particular, understands how sanctions risks may arise and how to mitigate those risks. In London, our partners are recognized as a go-to source for insurers and reinsurers on sanctions matters. In Washington, D.C., our attorneys provide comprehensive and practical guidance covering U.S. sanctions developments that impact not only U.S.-based insurers and reinsurers but also non-U.S. entities that are impacted by U.S. extra-territorial sanctions. These partners in particular, supported by a talented and experienced team of other international trade partners, counsel and associates, provide daily support to many of the world’s largest (re)insurers.

With our in-depth familiarity with the laws in this area, our lawyers provide guidance on what companies cannot do, but -- just as importantly -- what they can do. This enables international businesses to pursue and maintain opportunities that are consistent with their policy objectives, and gives them the confidence to succeed in markets and business that others might avoid while at the same time managing the compliance risk.

Representative Matters

  • Advising insurer and reinsurer clients on the impact of the U.S. withdrawal from the Iranian nuclear deal and the impact of the E.U. Blocking Statute.
  • Providing guidance to insurers on the use of the sanctions and territorial exclusion clauses in light of the conflict of laws arising between U.S. secondary sanctions and the E.U. Blocking Statute.
  • Advising reinsurer controlled by U.S. persons on impact of the U.S. withdrawal from the Iranian nuclear deal.
  • Advising insurer and reinsurer clients on the developing U.S. Venezuela-related sanctions; the impact of designation of PdVSA and assisting clients to identify and mitigate risks.
  • Responding to almost daily sanctions compliance questions raised by International Group P&I insurers including underwriter guidance and assisting with due diligence enquiries both at the pre-bind and claims stages.
  • Advising marine insurers on impact of recent OFAC marine advisories and providing guidance on updating and developing due diligence procedures and compliance programs in light of the advisories.
  • Advising insurer on the extraterritorial scope of U.S. Russia-related sanctions and steps to be taken to limit Russia risk.
  • Providing regular internal sanctions training to underwriting and claims teams for International Group P&I insurers and for global insurer.
  • Providing guidance on internal sanctions compliance policies and procedures for global insurer and assisting with integration of financial crime program.
  • Reviewing existing sanctions policies and procedures and updating to take into account sanctions developments.
  • Providing advice and assistance to insurers in relation to due diligence enquiries made by third party suppliers.
  • Attending monthly sanctions working group meetings for global insurance client.
  • Advising global (re)insurers on implications of designation of Russian oligarchs and the businesses they own and control and providing guidance on practical considerations relating to termination of policies.
  • Planning and hosting full-week training program for insurer’s global compliance team on how to manage sanctions developments in a business-friendly manner.