Sanctions
Welcome to our Sanctions Hub. Here, you’ll find essential information on the sanctions regulations and required documentation. Select a country in the list below to access the specific requirements and ensure compliance in your global operations.
Sanctions High-risk Countries
This is a non-exhaustive list of sanctions high-risk countries/areas.
Lawfulness to Insure
Whilst it may be lawful for the member to trade to some of these countries/areas, it may not be lawful for The Swedish Club to insure.
Extended Enterprise
The Club’s ability to provide the usual level of service associated with the benefit of insurance may be severely affected by the risk appetite of its business partners (‘Extended Enterprise’), such as banks and reinsurers.
The Swedish Club’s own Sanctions Due diligence
The Swedish Club is under a legal obligation to conduct sanctions screening, for its own purposes, when selling an insurance product on lead-basis that relates to a specific voyage to a sanctions high-risk country.
The Swedish Club is unable to perform sanctions due diligence on behalf of members/assureds – who will need to conduct their own independent sanctions due diligence.1
Sanctions against Belarus include sanctions imposed by:
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
No situation requires a Sanctions Due Diligence Questionnaire since Belarus is landlocked.
Documents
No specific documents needed.
Attestation
Attestation not required.
Member Alerts / Circulars
Sanctions against Cuba include sanctions imposed by:
- United States
Sanctions Due Diligence Questionnaire
Required to be submitted for voyages to and from Cuba prior to The Swedish Club quoting insurance cover for:
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from Cuba)
Documents
The latest version of the form must be used.
Only to be submitted to The Swedish Club for voyage-specific insurance covers (e.g. SOL)
Attestation
Attestation not required.
Member Alerts / Circulars
Sanctions against Iran include sanctions imposed by:
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
Sanctions Due Diligence Questionnaire is required (found under “Documents”) to be submitted for voyages to and from Iran prior to The Swedish Club quoting insurance cover for:
- War AP (only when The Swedish Club is Claims Lead)
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from Iran)
To claims leader only
It is sufficient for the assured to submit a duly filled out Sanctions Due Diligence Questionnaire to The Swedish Club when it is the claims leader. As such, there is no need for assureds to provide the Sanctions Due Diligence Questionnaire when The Swedish Club is a following underwriter.
Cefor Members – Use same questionnaire for all insurance interests
All insurance companies belonging to Cefor (‘Cefor Members’) have agreed that, where several Cefor Members provide insurance cover for the same voyage, it is sufficient for the member/assured to fill out one Cefor Sanctions Questionnaire.
In practice, this means that if a voyage requires more than one Additional Premium (AP) insurance (e.g. both Ice AP and War AP), it will only be necessary for the member/assured to fill out one Sanctions Due Diligence Questionnaire – assuming that both the H&M lead and War lead are Cefor Members. The same questionnaire can then be sent to H&M and War lead respectively.
Documents
The latest version of the form must be used.
Only to be submitted when The Swedish Club is Claims Lead or for voyage-specific insurance covers (e.g. SOL)
Attestation
Attestation not required.
Member Alerts / Circulars
Sanctions against Libya include sanctions imposed by:
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
Sanctions Due Diligence Questionnaire is required (found under “Documents”) to be submitted for voyages to and from Libya prior to The Swedish Club quoting insurance cover for:
- War AP (only when The Swedish Club is Claims Lead)
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from Libya)
To claims leader only
It is sufficient for the assured to submit a duly filled out Sanctions Due Diligence Questionnaire to The Swedish Club when it is the claims leader. As such, there is no need for assureds to provide the Sanctions Due Diligence Questionnaire when The Swedish Club is a following underwriter.
Cefor Members – Use same questionnaire for all insurance interests
All insurance companies belonging to Cefor (‘Cefor Members’) have agreed that, where several Cefor Members provide insurance cover for the same voyage, it is sufficient for the member/assured to fill out one Cefor Sanctions Questionnaire.
Documents
The latest version of the form must be used.
Only to be submitted when The Swedish Club is Claims Lead or for voyage-specific insurance covers (e.g. SOL)
Attestation
Attestation not required.
Members Alerts / Circulars
Sanctions against Myanmar include sanctions imposed by:
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
Sanctions Due Diligence Questionnaire is required (found under “Documents”) to be submitted for voyages to and from Myanmar prior to The Swedish Club quoting insurance cover for:
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from Myanmar)
Documents
The latest version of the form must be used.
Only to be submitted to The Swedish Club for voyage-specific insurance covers (e.g. SOL)
Attestation
Attestation not required.
Member Alerts / Circulars
Sanctions against North Korea include sanctions imposed by:
- United Nations
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
It is highly likely that no insurance cover is available for port calls to North Korea given the comprehensive nature of the sanctions imposed.
Documents
Individual assessment of documentation required will be made by The Swedish Club. In all likelihood, no insurance cover is available.
Attestation
Attestation not required.
Members Alerts / Circulars
Sanctions against Russia include sanctions imposed by:
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
Sanctions Due Diligence Questionnaire is required (found under “Documents”) to be submitted for voyages to and from Russia prior to The Swedish Club quoting insurance cover for:
- War AP (only when The Swedish Club is Claims Lead)
- Ice AP (only when The Swedish Club is Claims Lead)
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from Russia)
To claims leader only
It is sufficient for the assured to submit a duly filled out Sanctions Due Diligence Questionnaire to The Swedish Club when it is the claims leader. As such, there is no need for assureds to provide the Sanctions Due Diligence Questionnaire when The Swedish Club is a following underwriter.
Cefor Members – Use same questionnaire for all insurance interests
All insurance companies belonging to Cefor (‘Cefor Members’) have agreed that, where several Cefor Members provide insurance cover for the same voyage, it is sufficient for the member/assured to fill out one Cefor Sanctions Questionnaire.
In practice, this means that if a voyage requires more than one Additional Premium (AP) insurance (e.g. both Ice AP and War AP), it will only be necessary for the member/assured to fill out one Sanctions Due Diligence Questionnaire – assuming that both the H&M lead and War lead are Cefor Members. The same questionnaire can then be sent to H&M and War lead respectively.
Documents
The latest version of the form must be used.
Only to be submitted when The Swedish Club is Claims Lead or for voyage-specific insurance covers (e.g. SOL).
Submitted if the cargo carried is a G7 price-capped cargo. To be submitted for all voyages – both lead and follow – irrespective of insurance class.
Attestation
Attestation is required for each voyage with G7 price-capped cargoes.
Member Alerts / Circulars
Sanctions against South Sudan include sanctions imposed by:
- United Nations
- United States
Sanctions Due Diligence Questionnaire
No situation requires a Sanctions Due Diligence Questionnaire since South Sudan is landlocked.
Documents
No specific documents needed
Attestation
Attestation not required.
Member Alerts / Circulars
Sanctions against Syria include sanctions imposed by:
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
Sanctions Due Diligence Questionnaire is required (found under “Documents”) to be submitted for voyages to and from Syria prior to The Swedish Club quoting insurance cover for:
- War AP (only when The Swedish Club is Claims Lead)
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from Syria)
Documents
The latest version of the form must be used.
Only to be submitted when The Swedish Club is Claims Lead or for voyage-specific insurance covers (e.g. SOL)
Attestation
Attestation not required.
Member Alerts / Circulars
Sanctions against Occupied parts of Ukraine (including Crimea, Donetsk, Luhansk, Kherson, Zaporizhzhia regions) include sanctions imposed by:
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
Sanctions Due Diligence Questionnaire is required to be submitted for voyages to and from occupied parts of Ukraine (including Crimea, Donetsk, Luhansk, Kherson, Zaporizhzhia regions) prior to The Swedish Club quoting insurance cover for:
- War AP (only when The Swedish Club is Claims Lead)
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from occupied parts of Ukraine (including Crimea, Donetsk, Luhansk, Kherson, Zaporizhzhia regions))
To claims leader only
It is sufficient for the assured to submit a duly filled out Sanctions Due Diligence Questionnaire to The Swedish Club when it is the claims leader. As such, there is no need for assureds to provide the Sanctions Due Diligence Questionnaire when The Swedish Club is a following underwriter.
Cefor Members – Use same questionnaire for all insurance interests
All insurance companies belonging to Cefor (‘Cefor Members’) have agreed that, where several Cefor Members provide insurance cover for the same voyage, it is sufficient for the member/assured to fill out one Cefor Sanctions Questionnaire.
In practice, this means that if a voyage requires more than one Additional Premium (AP) insurance (e.g. both Ice AP and War AP), it will only be necessary for the member/assured to fill out one Sanctions Due Diligence Questionnaire – assuming that both the H&M lead and War lead are Cefor Members. The same questionnaire can then be sent to H&M and War lead respectively.
Documents
The latest version of the form must be used.
Only to be submitted when The Swedish Club is Claims Lead or for voyage-specific insurance covers (e.g. SOL)
Attestation
Attestation not required.
Member Alerts / Circulars
Sanctions against Venezuela include sanctions imposed by:
- United States
Sanctions Due Diligence Questionnaire
Sanctions Due Diligence Questionnaire is required to be submitted for voyages to and from Venezuela prior to The Swedish Club quoting insurance cover for:
- War AP (only when The Swedish Club is Claims Lead)
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from Venezuela)
To claims leader only
It is sufficient for the assured to submit a duly filled out Sanctions Due Diligence Questionnaire to The Swedish Club when it is the claims leader. As such, there is no need for assureds to provide the Sanctions Due Diligence Questionnaire when The Swedish Club is a following underwriter.
Cefor Members – Use same questionnaire for all insurance interests
All insurance companies belonging to Cefor (‘Cefor Members’) have agreed that, where several Cefor Members provide insurance cover for the same voyage, it is sufficient for the member/assured to fill out one Cefor Sanctions Questionnaire.
In practice, this means that if a voyage requires more than one Additional Premium (AP) insurance (e.g. both Ice AP and War AP), it will only be necessary for the member/assured to fill out one Sanctions Due Diligence Questionnaire – assuming that both the H&M lead and War lead are Cefor Members. The same questionnaire can then be sent to H&M and War lead respectively.
Documents
The latest version of the form must be used.
Only to be submitted when The Swedish Club is Claims Lead or for voyage-specific insurance covers (e.g. SOL)
Attestation
Attestation not required.
Member Alerts / Circulars
Sanctions against Yemen include sanctions imposed by:
- European Union
- United Kingdom
- United States
Sanctions Due Diligence Questionnaire
Sanctions Due Diligence Questionnaire is required to be submitted for voyages to and from Yemen prior to The Swedish Club quoting insurance cover for:
- War AP (only when The Swedish Club is Claims Lead)
- Voyage-specific insurance covers (e.g. SOL for a deviation relating to a voyage to/from Yemen)
To claims leader only
It is sufficient for the assured to submit a duly filled out Sanctions Due Diligence Questionnaire to The Swedish Club when it is the claims leader. As such, there is no need for assureds to provide the Sanctions Due Diligence Questionnaire when The Swedish Club is a following underwriter.
Cefor Members – Use same questionnaire for all insurance interests
All insurance companies belonging to Cefor (‘Cefor Members’) have agreed that, where several Cefor Members provide insurance cover for the same voyage, it is sufficient for the member/assured to fill out one Cefor Sanctions Questionnaire.
In practice, this means that if a voyage requires more than one Additional Premium (AP) insurance (e.g. both Ice AP and War AP), it will only be necessary for the member/assured to fill out one Sanctions Due Diligence Questionnaire – assuming that both the H&M lead and War lead are Cefor Members. The same questionnaire can then be sent to H&M and War lead respectively.
Documents
The latest version of the form must be used.
Only to be submitted when The Swedish Club is Claims Lead or for voyage-specific insurance covers (e.g. SOL)
Attestation
Attestation not required.
Member Alerts / Circulars
1
Recommendations to Members
Legal Advice for Sanctions High-risk Trades
The Club recommends all Members contemplating trade to or from sanctions high-risk country/region to seek external legal advice to ascertain the legality of the trade.
Members are expected to perform sanctions due diligence prior to entering into any contract (whether a charterparty or other type of contract) that may expose the Member and/or the Club and its reinsurers to the risk of sanctions.
When quoting for an insurance product, it often assists the Club to be provided with a copy of any sanctions legal advice obtained by the member.
Sanctions Clause in Commercial Contracts and Charterparties
The Club strongly advises Members to include appropriate sanctions language and sanctions clauses in their commercial contracts and charterparties.
Members to conduct own Sanctions Due Diligence
The Club is not a position to perform sanctions due diligence on behalf of Members for an intended trade.
Members may need to obtain independent legal sanctions advice to ensure the legality of an intended trade.
Sanctions Compliance Practices
For more information on Sanctions Compliance Practices, we refer Members to Guidance for owners and charterers on sanctions compliance practices.
Service Level
Level of Service – Sanctions High-risk Countries/Regions
The Club always strive to service Members. There are, however, times when providing the normal service-level may not be possible due to prevailing sanctions or risk appetite of the Club’s Extended Enterprise (for instance, banks and reinsurers).
These instances include, but are not limited to, the Club being unable to:
- Make transactions due to the prevailing risk appetite of the Extended Enterprise;
- Appoint and pay correspondents or other service providers in sanctions high-risk countries/regions;
- Appoint and pay correspondents or other service providers where the trade (including cargo on board the ship) is to or from a sanctions-high risk country/region – even though the service provider is located in a low or medium sanctions risk country/region; and
- Provide security (such as Letters of Undertaking or bank guarantees) due to applicable sanctions, which may impact the Club’s ability to pay under a Letter of Undertaking.
Insurance Cover
Insurance cover is subject to the applicable insurance conditions and/or Rules. All Club Rules and insurance conditions contain sanctions clauses.
It is possible that a certain sanctions regime may not be directly applicable to the Club and/or its Members. Yet, it may still expose the Club and its Members to serious risks if the Club and/or its Members are in breach of such sanctions regimes
Cover under the Club’s P&I Rules and Rules for Charterers’ Liability Insurance
The Club’s position, in line with that of other P&I Clubs, is that all Members are under an obligation to take steps to ensure the legality of their own actions. Members are also under an obligation not to engage in unlawful trade, see inter alia P&I Rules 10 and 11 and Charterers’ Liability Insurance Rules 18 and 19. Where an insured ship engages in unlawful trade, there is no cover.
In more severe situations – where breach of sanctions has been made with knowledge of the Member – there is a risk that the insurance cease altogether pursuant to P&I Rule 27 (e) or Charterers’ Liability Insurance Rule 32 (e).
Where a Member has exposed or may expose the Club to the risk of being or becoming subject to a sanction, prohibition or other adverse action under certain sanctions regimes, the Club may terminate the period of insurance on such notice as the Club see fit, see inter alia P&I Rule 26 and Charterers’ Liability Insurance Rule 31.
Sanctions legislation affecting the Club and its reinsurers may also impact Club cover. Pursuant to P&I Rule 11 Section 4 and Charterers’ Liability Insurance Rule 18 section 4, liabilities may be excluded from cover in case payment of a claim is likely to expose the Club or any of its reinsurers to any sanction, prohibition or adverse action. The provision of security (e.g. Letter of Undertaking or bank guarantee) is discretionary. See inter alia P&I Rule 12 and Charterers’ Liability Insurance Rule 19.
Cover under the Club’s FD&D Rules and Charterers’ FD&D Rules
The Club’s FD&D Rules and Charterers’ FD&D Rules contain the equivalent provisions to those set out in the P&I Rules and Charterers’ Liability Insurance Rules. See inter alia concerning unlawful trade FD&D Rule 10 section 2 and Charterers’ FD&D Rule 10 section 2, termination: FD&D Rule 23 and Charterers’ FD&D Rule 22 as well as cesser: FD&D Rule 24 and Charterers’ FD&D Rule 23.
Cover is, as for all FD&D disputes, in the absolute discretion of the Club, see inter alia FD&D Rule 5 and Charterers’ FD&D Rule 5.
Cover under the Club’s Marine Insurance
In relation to Marine insurance, the Club incorporates its mandatory club clause W.10 Sanction limitation and Exclusion Clause. Under the clause, no insurer shall be deemed to provide cover nor be liable to pay any claim or provide any benefit under the insurance to the extent the provision of such cover, payment or benefit would expose the Club, any other insurers involved on the risk or its reinsurers to any sanction, prohibition or restriction due to sanctions.
Marine insurance is provided on market terms of either the Nordic Marine Insurance Plan, ITC or ADS/DTV conditions and is as such also subject to any sanctions clauses that may be mandatorily incorporated in the relevant set of standard terms. By way of example, clause 2-17 of the NMIP is such a clause. For other standard terms, specific sanctions clauses may be customarily used together with them, such as the Joint Hull Committee’s standard clause being used with ITC conditions.
Disclaimer
Information on this site
This information has been put together with care. Information is not exhaustive and overview only.
The Swedish Club does not guarantee that the information is accurate and up to date.
Vessel Monitoring
In line with the agreement of the International Group of P&I Clubs as set out in Circulars – P&I – No: 2658/2020, the Club monitors its entire insured fleet.
Questions?
In case of Members have any further questions regarding sanctions and Club cover, please contact the Club’s FD&D claims handlers.