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Author: Andreas Krebs

Head of Insurance Mediation Services

Update on Insurance in Ukraine: Money Transfers Between Insurers and Reinsurers Possible Again

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Overall insurance capacity on the local market remains rather low. Since beginning of this year, there is no more cover for SRCC, terrorism and sabotage available.

At the day of the outbreak of war in Ukraine, February 24th, 2022, the Ukrainian government introduced martial law in the country, which meant among other stipulations that money transfers were limited to a very small number of transactions. The intention behind this was to create the list of services and products for critical import need only and protect Ukrainian currency against speculation and depreciation. The international payments from Ukraine were stopped, which lead to the substantial decrease of the local insurance capacities.
 
Within 2022 the list of critical import was reviewed and expanded and now, the National Bank of Ukraine (NBU) has revised this policy by a decision of February 14th, 2023, to allow money transfers in the financial sector.
 
 Each local insurer has to apply anew for the authorization of premium and claim payment transfers; the insurer will then be listed as authorized company by NBU.
 
Authorization will be granted to insurers which did not violate the strict money transfer and special economic sanction regime valid since the beginning of the war. Insurance companies in Ukraine have to show in full transparency their ownership structure, solvency standards, capital adequacy and risk operations and they have to prove the good business reputation as a company and that of their owners and managers. Money transfer will be possible to non-resident reinsurers with a rating level not lower than “A3” (Moody’s), “A-” (Standard & Poor’s), “A-” (Fitch Ratings), “A-” (A.M. Best).
 
It cannot be said, however, that these new transfer possibilities lead to a renewed interest of “Western” insurers and reinsurers to offer capacity for Ukrainian risks. Existing reinsurance treaties will be honored and the support for local insurers will be given to a certain extent, but market opinions indicate that “Western” reinsurance markets will still be reluctant to engage themselves in Ukraine due to the open war situation.
 
Ukrainian insurance market data from 3rd Quarter 2022, the newest ones available, show a 21.4 % decline in Non-Life insurance and a 13.85 % decline in Life, leading to an overall premium volume in the first three quarters of last year of UAH 25 billion (EUR 625 million).
 
Overall insurance capacity on the local market remains rather low. Since beginning of this year, there is no more cover for SRCC, terrorism and sabotage available.
 
We shall keep you informed regularly on any new development on this market.

The article is written by Andreas Krebs and Tetyana Mieshkova.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

Andreas Krebs

Tetyana Mieshkova

GrECo / MAI Ukraine

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Latest news from the Russian insurance market 2022/2023

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News from the Russian insurance market 2022/2023

As we reported earlier, after the outbreak of the war in Ukraine Russia and Belarus have been cut off from the Western international insurance markets by regulations put into force by both the European Union and the Russian Federation.

GrECo and MAI decided to leave Russia, but since it is very important for us to support our clients and those of our business partners worldwide, we opted for continuity and sold our companies to the local management headed by Andrey Panov, who will run the company on the local market as Russian company Nobilis Brokers. In this update of our report, we want to give broad information on news from the market in Russia, as there have been many changes during 2022 and many developments may still come.

Status of insurance in Russia

The Russian insurance market consists of 222 market players (146 Insurers, 58 licensed insurance brokers and 19 other insurance related companies – based on official report, provided by the Central Bank dd. 01/04/22), but their number is decreasing (e.g. minus 7 within one year).
 
After the restrictive measures taken by the state in connection with Covid-19 in 2020/2021, the insurance industry was recovering, but the outbreak of hostilities in Ukraine had huge consequences on the local market during last year..

  • The market is cut off from international reinsurance – so capacities offered shrink to the net capacities of insurers plus capacity of Russian National Reinsurance Company (RNRC) that has been strengthened in its role by a capital increase by Russian National Bank;
  • All Russian insurance companies have to offer RNRC 50% line in all outward reinsurance business (the compulsory ceding RNRC by Russian insurers was increased from 10% to 50% of reinsurance order, in accordance with Law FZ 46 dd.08/03/22);
  • The financial security of Russian insurers (satisfactory in the past) will worsen substantially, rated international reinsurance is not going to be available for some time to come;
  • There are currently four Russian insurers being under EU and/or US sanctions: SOGAZ, Rosgosstrakh, SberInsurance (non SDN list) and Sovkombank Insurance. Sanctions do, of course, not apply for purely Russian business, for instance if the Russian subsidiary of an international group buys insurance on the Russian market.
  • Russian insurance companies continue business using their own increased capacity (co-insurance schemes for bigger risks) and increased reinsurance by RNRC.
  • For the time being, the financial data of Russian companies are not to be disclosed due to an order by the Central Bank of Russia.
  • The main local Insurers at the local market are: Sogaz, Ingosstrakh, Sberbank, AlfaStrakhovanie, VSK.
  • During the first six months of the insurance legislation in 2022 main international insurers were to stop their business activity (they decided to put a ban on quotes and policy issuance for new business and even renewals), but none of them has declared its exit.

The situation with Western insurers that have been working in Russia is as follows:

  • Zurich Russia sold the business to new Russian owners and was rebranded – the new name is Turicum”;
  • AIG Russia sold the business to new Russian owners; it was rebranded at the end of 2022 – the new name is “Gardia”;
  • Chubb Russia has not announced further decisions regarding the Russian entities; right now they cannot issue new or renew expiring policies;
  • Allianz Group sold a majority stake in its Russian operation to InterHolding LLC, the owner of Russian P&C insurer Zetta Insurance. Allianz Russia holds a minority stake of 49.9% in the combined company;
  • HDI Russia still continues operating business activity with no change during 2022.

Risks located in Russia not any longer covered by International Programs

Coverage in a global insurance program with local fronting policies is now unavailable for risks located in Russia due to the territorial exclusion clauses of Western insurers and the impossibility to integrate Russian policies for lack of international reinsurance. Thus the only option is local stand-alone insurance with purely Russian Insurers.  

Market tendencies

The following tendencies can be observed on the market:

  • In general, Russian insurers are ready to place traditional lines (PDBI, TPL/ PL/ EL. PI, cargo and D&O), however it is still a hard market for the line Fidelity/Crime (difficult and expensive to place);
  • Insurance tenders are subject to preliminary providing very detailed underwriting information (filled in insurance questionnaire on each insurance line);
  • Tenders take longer and usually the insurance offer is valid for 30 days only;
  • The main T&C with the local insurers may differ from former policies that were part of global programs (lower limits, different wording); the prices for such policies are likely to be higher;
  • Increased interest for “terrorism” and “war” cover in all lines (but mainly in property and cargo); but most local insurers, on the contrary, extend exclusions of territory coverage (due to war risk);
  • Due to very poor loss statistics within the last years on the local insurance market in respect of warehouses (stock insurance) and 2 total losses, well-noted at the local market (Ozon warehouse and OBI store), lots of local carriers are either not interested in providing the coverage or need at least very detailed info on the location (or may be a survey carried out by their engineers) for even giving a quote;
  • Despite the current situation, there is an increase of motor insurance (values of the car/ spare parts were increased, change of “basis rate” for CMTPL policies) as well as cargo and property insurance (for legal entities).

Local support provided by Nobilis Brokers

Telephone and internet communication with Russia is working despite the current political situation. For more detailed information on insurance in Russia and for support for insuring or placing risks Nobilis Brokers can be contacted directly by e-mail: A.Panov@nobilisbrokers.ru .
 
(Details of this report have been provided by Andrey Panov and Anna Dyachenko, Nobilis Brokers).

The article is written by Andreas Krebs.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

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The Price Cap on Russian Oil – Implications on Insurance

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The Price Cap on Russian Oil – Implications on Insurance

Many insurers including insurance brokers will now be able to provide insurance services for Russian crude oil shipments to countries which are not part of the Price Cap Coalition provided that the price of the Russian crude oil cargo from the time it is loaded until it has cleared customs at the port of destination is at or below $60 per barrel.

The EU, G7 and Australia (the “Price Cap Coalition”) have recently introduced legislation and guidance effective 5 December 2022 intended to maintain the supply of Russian oil to world markets whilst at the same time reducing Russia’s earnings from its oil exports (the “Price Cap Scheme”).

Under the Price Cap Scheme, various insurers including insurance brokers will now be able to provide insurance services for Russian crude oil shipments to countries which are not part of the Price Cap Coalition provided that the price of the Russian crude oil cargo from the time it is loaded until it has cleared customs at the port of destination is at or below $60 per barrel (the “Price Cap”). A separate price cap will be introduced on 5 February 2023 for Russian petroleum products.

Ships with Russian crude oil on board on the 5 December commencement date may continue to lawfully perform the voyage even if the cargo has been sold at a price above the Price Cap if the voyage will be completed and the cargo offloaded by 19 January 2023.

Rules for insurance of Russian oil shipments

Insurers, insurance brokers, shipowners and charterers will now be required to check the price of Russian oil cargoes on board ships they own, charter or insure. These checks will take the form of contractual attestations provided by their contractual counterparties stating that for the relevant period the price will not exceed the Price Cap.

A Cargo owner or shipowner or Charterer that intends to transport Russian crude oil cargoes after 5 December will now need to provide its insurance service providers with an attestation that it will not for the duration of the period of insurance carry Russian oil cargoes which have been sold at a price that for the period during the voyage has exceeded the Price Cap. This attestation will be required for all types of Marine insurance.

Insurance cover for the carriage of Russian crude oil loaded after 5 December 2022 and petroleum products loaded after 5 February 2023 is dependent on various insurers complying in full with the requirements of the price cap schemes, including the provision of appropriate attestations. Insurers will be required to withdraw cover where there are reasonable grounds to suspect that the carried cargo was purchased at a price greater than the price cap..

Price Cap is part of the sanction regime

Under the Price Cap scheme, those persons that are subject to the jurisdiction of the EU, G7 and other coalition partners such as Australia will be prohibited from transporting and/or providing services (including insurance services) that enable the transportation of Russian origin crude oil and oil/petroleum products unless it has been sold at or below the Price Cap. The prohibition on services provided by a service provider based in an EU, G7 or other coalition partner jurisdiction extends to shipments by or to third countries that are not part of the EU / G7 coalition and to that extent will have an extra-territorial effect.

Please note that various price cap schemes largely mirror each other but there are significant differences between them. For example, the period during which the Price Cap must apply to benefit from the EU Price Cap scheme is longer than under the equivalent UK and US legislation. Under the EU scheme even where the oil has cleared customs at the third country destination in circumstances where it then “…becomes seaborne again without being substantially transformed into a different good in line with non-preferential rules of origin. (i.e. without being refined) … the price cap will still apply.”

Again, parties are expected to obtain appropriate attestations of cargo price the nature of which will depend on which Tier they fall into. The definition of the Tiers by the EU is the same as that adopted by the UK and US with shipowners and various insurance service providers identified as Tier 3 Actors. Parties are required to keep records of Price Cap transactions for five years.

For example, shipowners are considered Tier 3 Actors by all three jurisdictions. As such, a Shipowner must obtain a contractual commitment from its contractual counterparty – usually the charterer – that its counterparty has committed not to purchase Crude Oil or Petroleum Products above the Price Cap. Such an Attestation may be a stand-alone document or included within a wide contract.

Validity of cover as long as Price Cap is respected

Various stakeholders should note that from 05:01 GMT 5 December 2022, insurance cover for Russian Crude Oil Price Cap cargoes is conditional upon the unit price of the Russian Crude Oil supplied or delivered, or being supplied or delivered, being at or below the Price Cap. To comply with the Price Cap scheme insurers are required to withdraw cover in circumstances where there are reasonable grounds to suspect that the Price Cap attestations provided are false and/or where the cargo is sold after the voyage has commenced at a price greater than the Price Cap. Where a breach is identified after loading vessels may be left uninsured and without access to normal banking services for an extended period whilst the authorities determine how best to dispose of the cargo.

First reactions concerning insurance

According to Business Insurance online of December 12th, 2022, Russian insurer Ingosstrakh declined to insure oil cargoes not compliant with the price cap. Insurance will only be available on the same requirements as for the “Western” insurers.

Turkey’s maritime authority said it would continue to block the passage of oil tankers without appropriate insurance letters, adding that the insurance checks on ships in its waters was a routine procedure, with a focus on transit through the Bosporus Strait or calls at Turkish ports.

The article is written by Andreas Krebs and Kristo Ristikivi.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

Kristo Ristikivi

Group Practice Leader Cargo

T+372 506 9809

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End of International Coverage for Russia / Belarus / Ukraine?

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End of International Coverage for Russia / Belarus / Ukraine?

In the negotiations taking place on contract renewal, it has turned out that the international insurance industry is no longer willing to agree on coverage for Russia and Belarus, and the options for coverage in Ukraine are also very limited.

Since it began, the Russian aggression against Ukraine has led to numerous economic changes, the scope of which still cannot be fully assessed. Keywords such as energy crisis, inflation, stagflation or even recession dominate international reporting, lectures and discussions. The insurance industry’s core business was affected by the consequences of the war from the start. In the beginning, there was the withdrawal of “Western” reinsurers from the Russian market, followed by the self-isolation of the Russian insurance market and the interruption of cross-border payment flows due to the declaration of martial law in Ukraine.

Both markets – Belarus plays a subordinate role here given the low level of international trade and investments – were thus isolated, but insurance cover was still available locally, albeit with significantly reduced capacities, especially in Ukraine. It was therefore reassuring that international insurance programs were honoured during their remaining contract period in 2022 and coverage was provided for all three states involved in the war via the Financial Interest Clause of the master contract.

Territorial exclusion is an issue during insurance contract renewal

In the negotiations taking place on contract renewal, it has turned out that the international insurance industry is no longer willing to agree on coverage for Russia and Belarus, and the options for coverage in Ukraine are also very limited. It is, of course, the first time in decades that a war involving a major power is taking place that is being opposed and indirectly fought by other major powers, and this is probably the reason why insurers have not only focused on the exclusions of coverage briefly described below in connection with war and the imposition of sanctions but introduce a territorial exclusion for Russia, Belarus and Ukraine. This attitude is unique and must therefore be examined critically at this point. The exclusion clause, as also acknowledged by reinsurers, represents the last link in a three-part exclusion chain, a simple solution that avoids any discussion concerning a risk located in one of the countries.

Traditional: the War Exclusion Clause

Let us now take a closer look at this three-part set of exclusions.

The traditional precaution of the insurer against having to pay claims which would by frequency and amount destroy any insurance portfolio and might lead to a serious threat to the continued existence of the insurance company is the war exclusion anchored in the General Conditions, above all for property and liability insurance, although differently defined. In fire insurance (including business interruption!), the clause says that “damage caused by the direct or indirect effect of acts of war … including all acts of violence by states …” as well as “all military or official measures connected with the acts mentioned …” are not covered.

According to a newer definition, liability insurance does not provide insurance cover “for damage caused by acts of violence by states or against states and their bodies, acts of violence by political and terrorist organizations, …”. Both definitions are therefore very broad and general and will be checked by the insurer in the event of a claim in Ukraine and, if necessary, applied to decline payment of a claim. However, the burden of proof lies with the insurer – despite the contrary, contestable definition in property insurance that can sometimes be found. In any case, the insurer is protected against claims for war damage.

Sanctions prohibit insurance in certain areas

After the war broke out, the EU as well as the US and UK, responded with economic sanctions against Russia, specially designated Russian citizens and entities. The eight packages of sanctions of the EU now in existence are related to export and import restrictions for precisely named goods recorded in lists. Compliance with the sanctions is binding for legal and natural persons within the EU, disregarding them or circumventing the EU is a punishable offence. It follows that no insurance cover can be granted for sanctioned persons, organizations and goods, including their production, trade with them and transport.

In recent years – long before the war in Ukraine – insurers have therefore formulated sanctions clauses that exclude coverage for activities and goods subject to sanctions. The insurers’ exposure is thus further reduced since some sectors and products are now subject to sanctions for Russia. However, it must also be emphasized that the EU has expressly stated that there must be no product sanctions for food, sanitary articles, medicines and other products of humanitarian need. Although sanctions intend to affect the Russian economy, they should not contribute to punishing innocent citizens. It is therefore expected in the dialogue between insurance customers and insurers that the sanction clause will be checked for its specific applicability in individual cases when the insurance contract is concluded or in the case of a claim.

Territorial exclusion reduces the value of the International program

These two clauses, which are justified and allow an examination of the individual case and represent at least some protection of the insured if a claim is not due to war or in connection with sanctions, are now accompanied by territorial exclusion as a third clause. Its application means that the insurer no longer has to deal in any way with risks, contracts or claims in any of the countries concerned. It is therefore an a priori refusal of cover, which has only seldom been seen in this form up to now. It has not even been applied to the famous “rogue states”.

Insurance lawyers will object here that there is no obligation to contract in industrial insurance and that the insurance company can refuse to assume a risk at any time. The legal provisions on the increase in risk even suggest that an insurer does not have to assume a risk that it considers to be high. This is correct, but for reasons of fairness alone, an insurer who is willing to insure known risks worldwide as part of an international insurance program should not start excluding individual countries. If such an example catches on, it’s not far to the erosion of the insurance program, when other countries that are problematic for whatever reason, like China, Iran and whoever, are put on the exclusion list.

Another often-heard argument for this exclusion is compliance: it is not appropriate to continue to support the Russian economy and this also applies to insurance and reinsurance. As with other measures, however, the one who ultimately suffers is not the warring state of Russia, but the policyholder who has gone to the countries of Eastern Europe with his activities. He is now told that he can insure his risks locally, which is a very weak alternative given the limited capacities in Russia or the scarcity of insurance sums in Ukraine. Comparable to accepting a high degree of underinsurance.

Individual solutions required

Nevertheless, we are confident that in individual cases it will be possible to obtain coverage in the country of the master treaty when it comes to risks with a humanitarian context, when the risk locations are not directly in war-affected areas of Ukraine, when the volume of insurance in one of the states concerned is small compared to the rest of the world, when transports between third countries involving one of the three states have to be insured, etc. It is worthwhile to negotiate with the insurance industry on an individual basis, at least to arrive at a compromise solution, such as coverage with a review clause in the event of a clear escalation of the war.

The article is written by Andreas Krebs.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

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Transformation in Global Insurance

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Transformation in Global Insurance

After a series of big mergers at the end of the last century and a period of increasing financial stability, global insurance is now heading for a time of disruption and changing parameters: Climate change, pandemics, war and sanctions are becoming a part of the Western world. Inflation, digitisation, demographics and changes in work behaviour are among the most important factors affecting an industry that is still solidly based on 19th-century economic principles. How will global insurance and reinsurance adapt to new challenges and navigate the stormy waters of the 21st century?

It would be an exaggeration to speak of a “historical turning point” in the insurance industry, a term politicians nowadays use to describe global changes related to the war in Ukraine. Rather, we see a constant flow of changes having been made possible by technical improvements – both in know-how and advances in IT – as well as by management decisions, some of which set new directions in the development of this industrial sector.

A quarter of a century ago, when insurance managers were unsure if their clients’ data would survive the turn of the century because computers might not be able to recognise the new millennium, as the number ’99’ denoted contracts without a specific expiration – a phenomenon called the Y2K bug – there was even greater concern with respect to the level of operating costs. Too many employees administrated contracts and sold insurances only with the help of heaps of paper because IT was far from being fully automated. The answer to this was to merge companies to at least reduce overheads by creating a greater span of control. Statistics based on past premium and loss ratios, the “burning cost” method only considered past losses, and model calculations of future loss scenarios were too complicated and insufficient. Companies could only compensate for this situation with relatively high premiums, lower average wages, and substantial capital gains due to higher interest rates.

Technological transformation of the insurance world

The rapid development of IT office tools in the first years of the new century brought about a revolution (not only) in industrial risk calculation. For the first time, NatCat scenarios could be comprehensively evaluated and forecasts made, at least for catastrophes due to weather events. The tremendous development of access to the Internet made data collection from all parts of the world much easier. This has brought stability to the portfolio as insurers have gained a better understanding of the cost of claims that might be expected in the future.
 
Of course, losses from natural catastrophes increase further, there is a higher frequency and extent of individual events due to climate change and the concentration of insured goods in exposed areas, such as densely populated settlements on the coasts. These developments can still be included in the calculation of premiums. However, the weather phenomena that have increasingly occurred in recent years are a cause of great concern because their effects are longer lasting than those of individual events. First and foremost, it is the rise in temperature, especially in large cities, and large-scale droughts that claim numerous lives and destroy property every year. Especially in the case of agricultural risks, the limit of global insurance capacities is being reached. Hence, other means of compensating for damages must be found, often by the states themselves.
 
The insurance industry is therefore quite willing to adopt the efforts needed to achieve the Paris climate goals and other measures specified by EU legislation, such as the Taxonomy Regulation. For the time being, the leverage consists in restricting investments in companies that do not (or no longer) comply with the taxonomy as well as in refusing to insure such risks – the most typical example, at the moment, is coal. This strategy, known as “Net-Zero”, aims to encourage the transition to new processes for generating energy and new production methods in various industrial sectors.

Increased willingness to take over new risks

In the new millennium, great progress was also made in reducing the risk of fire through new, safer industrial processes, but above all through a greater awareness in companies for fire protection measures. This was one of the main drivers of the so-called soft market over the past two decades, which was not only a result of the commercial strategies of insurers. It is astonishing that this market behaviour has lasted for so long, despite insurers facing a constantly declining income from investments. At the same time, the results from sole insurance activities, defined by the “combined ratio” (= premium less claims and costs), have constantly improved.
 
This has also increased the willingness to take over risks that were previously considered uninsurable or very difficult to insure. These include the aforementioned natural hazards, including earthquakes, but also an ever-increasing expansion of coverage in business interruption insurance to cover risks associated with supply chains. It now seems that there are new restrictions concerning either the cover itself or individual premium corrections that are still pending. Hence, we may see a return to the hard market.
 
These transformation processes in technical, risk-related areas are not yet that spectacular. In fact, insurers are contemplating whether or not they should continue to have the same structure as in the past – as large, personnel-intensive companies that handle the entire business process from the first customer contact to the settlement of claims, from the maintenance of large office buildings to comprehensive processing of their own data. A number of external factors are responsible for the fact that it is more likely that these organisations will be split into small special units with increased outsourcing. In the ​​ core business, capacities are already being shifted back to special companies and outsourced underwriting agencies. Other areas, such as building management or data processing, are also suitable candidates.

Insurance transformation and Covid-19 pandemic

The Covid-19 pandemic – which has led to different financial burdens on individual insurance markets – has fundamentally changed the professional world through the widespread use of home office work solutions. Insurance is a particularly labour-intensive sector of the economy, but it has the great advantage that most of the work does not necessarily have to be carried out at the location of the company. Thus, home office work solutions will, at least partially, become the new norm in the insurance business of the future, with all the consequences, such as fewer office space requirements, more powerful IT systems and a stronger focus on social issues on part of management.
 
Even before the outbreak of the pandemic, there were intense discussions as to whether the sales process could be shifted to the Internet, just like in other business sectors, which would mean a drastic reduction in sales staff. Findings thus far show that the insurance customer likes to search for information and offers electronically, but still prefers the advice of a physical person when concluding an insurance contract. This can be explained by the complexity of insurance products as well as by the fact that most people interested in insurance would rather entrust their sensitive data to a person than to a machine. However, we can expect that future generations of “digital natives” will increasingly conclude their insurance contracts online. The insurance sector is therefore also investing in expanding its online options, for the time being primarily in products that require little explanation. The number of such products might increase in the more traditional or core areas of private insurance as well. The widespread shortage of skilled workers could fast-track this transformation.
 
However, insurance advisors do not have to worry that their work and jobs will become obsolete. On the contrary, providing expert advice about products will still remain their main task -, especially in corporate insurance, where the role of the advisor will gradually shift to ​​risk evaluation and risk management. Additionally, they will also continue to provide certain ancillary services.
 
As mentioned above, insurers have significantly increased their willingness to take on new and additional risks in recent decades. In addition to the property insurance risks, new offers in terms of so-called Financial lines, covers such as D&O and Cyber, and even more special solutions are now a standard, not just for large companies. Currently, some rethinking seems to be taking place, partially initiated by the war in Ukraine. Insurers are rediscovering the possibility of saying “no” to certain risks across the board. An example is the exclusion of entire territories from cover, such as Russia, or the withdrawal from certain exposed sectors, such as Cyber. The principle that “everything is insurable as long as there is an adequate premium for the risk” is overridden when other fundamental factors such as the principles required by governance and compliance come into play.
 
Other challenges, such as the current inflation and the continued low investment income, which will probably also lag behind inflation in the near future, will not be discussed here due to a lack of space. These challenges have either subsisted for a long time or they keep coming back. The insurance industry has learned to live with them and is still able to report very good economic results every quarter.
 
In summary, the transformation in the insurance industry can best be described with an image: The market participants are developing from large tanker vessels, which operate with many sailors and use nautical charts made of paper, to fleets of small, largely automated ships, which are heading towards their ports of destination with the help of GPS .

The article is written by Andreas Krebs.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

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Beyond International Programs – Cover Exclusions for Russia, Belarus and Ukraine

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Insurance cover exclusion papers

For ongoing insurance programs with inception before the start of the Ukraine war, there is in most cases still insurance cover through the agreed home country Master contracts, DIC and FInC covers until next renewal.

The European insurance and reinsurance markets are currently not providing any new covers for property and business interruption risks in the territory of the Russian Federation, in Belarus and, with a few exceptions, in Ukraine. For ongoing insurance programs with inception before the start of the Ukraine war, there is in most cases still insurance cover through the agreed home country Master contracts, DIC and FInC covers until next renewal.
 
However, the geographical scope will be restricted for all upcoming renewals and new contracts, and the countries mentioned will thus generally be excluded from insurance cover. This primarily affects the designated locations previously insured under the programs, but the exclusion goes beyond that and applies equally to any non-specified risk and assets located in those territories. In the past, such risks were included in standard insurance contracts, for example, by special clauses for small foreign risks (offices, small storage places etc.) or by the automatic temporary inclusion of “New business locations”. In Business interruption, all supply-chain disruption and NPDBI endorsements may be concerned.
 
It should therefore be checked in all upcoming renewals whether there could be a gap in coverage because of the general exclusion of those territories, which has to be discussed with the client.  Unfortunately, the only remaining alternative is to try to buy insurance cover for these risks from local insurance companies with the support from our local co-broker.
 
Even if property insurance is the main topic here, it should be noted that a similar exclusion for risks that arise within the affected countries can also be expected to prevail in the other lines of insurance.

The article is written by Andreas Krebs.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

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War in Ukraine – impact on insurance

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In the event of war, insurance contracts generally continue to run until their natural expiry date, but coverage must be considered to be very limited, as losses directly or indirectly related to war events are excluded in almost all lines of business.

The war in Ukraine, which has been raging since February 24th, and the response of the Western world in the form of economic sanctions against Russia have so far had a drastic impact on the insurance industry. Insurance brokers who deal with risks located in Ukraine and Russia and whose clients include Russian legal entities or natural persons are therefore obliged to deal with these effects.

Insurance of risks in Ukraine

According to the insurance definition, the entire territory of Ukraine is to be classified as a war zone, and strict sanctions also apply to the territories of Crimea, Luhansk and Donetsk.

In the event of war, insurance contracts generally continue to run until their natural expiry date, but coverage must be considered to be very limited, as losses directly or indirectly related to war events are excluded in almost all lines of business. A grey area also arises in the case of losses that remain still covered, as obligations as a prerequisite for payment by the insurer cannot possibly be met. This will have to be assessed on a case-by-case basis.

Insurance companies outside Ukraine are not prepared to renew insurance contracts or write new business in view of the war situation and the associated imponderables for contract performance. Insurance companies based in Ukraine are currently operating in emergency mode and can only provide a very limited service. It must therefore be assumed that there will be great difficulties in providing proper insurance cover in Ukraine.

Insurance of risks in Russia

Russia itself is not a war zone, existing coverages and contracts are therefore in principle fully valid. However, Russia is affected by sanctions imposed by the UN, the EU, the USA and Great Britain, which include a ban on insurance services for certain persons, companies and entities as well as certain goods and productions (sectoral sanctions). These sanctions must be complied with by all citizens of the respective issuing states or communities of states under personal threat of punishment.

While it cannot be the task of the insurance broker to advise his clients on the sanctions associated with the delivery of goods or financial transactions, it is part of his service commitment to provide information on possibilities for insuring risks, insofar as these are legally permissible in the light of the sanctions, and to take appropriate measures to obtain insurance cover.

In addition to the sanctions briefly mentioned here, all Western insurers and reinsurers have now decided not to offer any new capacity to Russian insurers. The Russian Federation reacted to this at the beginning of this week and, for its part, has banned Russian insurers from cooperating with foreign partners – i.e. insurers and insurance brokers – from “unfriendly countries”, including all EU members, until the end of this year. Thus, Russia is isolated from the international insurance market. The major international insurance brokers have subsequently withdrawn from Russia, and insurers with subsidiaries in Russia will most likely follow.

If the interests of EU-domiciled clients in Russia now require insurance cover, the only recommended course of action is for the respective company representatives to contact a Russian insurance broker on site, who can then obtain the required cover. This is because from an EU perspective, insurance brokers, as well as other companies, are not allowed to contact most Russian insurers because they are on the sanctions list as described above. On the other hand, the Russian insurance market consists of several professional insurers, which are now backed by the Russian state reinsurance company, so that common insurance coverage seems to be available. However, it should be borne in mind that insurance is only possible in rubles, lower sums insured than those needed could only be obtained and the financial strength of these insurers will also suffer in the future as a result of the sanctions.

It is currently still being examined whether capacities for Austrian interests in Ukraine and Russia are available from Austrian or Western insurers within the concept of balance sheet protection (so-called FINC clause); expectations must be classified, however, as rather limited for the time being.

Insurance of Russian interests within the European Union, the UK and the US

The sanction regime outlined above also requires the verification of Russian interests in Western states. The media have already reported confiscations of the property of oligarchs on the Mediterranean or in Great Britain. In this sense, the provision of insurance in the EU, the United Kingdom and the United States to sanctioned persons or entities is also prohibited. If sanctioned persons are found in an existing portfolio, the insurance broker must also withdraw from these persons or entities and terminate the business relationship, preferably in consultation with the insurance companies concerned. In case of doubt, institutions such as the Chambers of Commerce or the Ministry dealing with the sanction regime provide information on whether a person or company or entity is subject to sanctions. However, it is expected that a preliminary check will be made by the broker using the published sanctions lists.

Belarus

Although the scope of economic ties with Belarus may be significantly smaller than that of relations with Russia, it can be assumed that, on the one hand, the sanctions will increasingly be applied to this country as well and, on the other hand, the Western insurance industry will completely withdraw from cooperation with local insurers.

Please note that all information is based on the current state of developments in this military conflict and changes may occur at any time.

The article is written by Andreas Krebs.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

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Current status of sanctions against Russia and certain Ukrainian territories

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EU sanctions prohibit any direct or indirect economic interactions (prohibition of payment and provision of services) with listed persons, as well as with all companies in which a listed legal entity or natural person has an ownership interest of 50% or more.

This is an overview of the current status of EU measures, with more focus on sanctions relevant to the financial sector/insurance (mediation) services. The summary includes the sanctions imposed in 2014 against Russia and Crimea, which are still in effect, and the sanctions most recently imposed in February of 2022 which are again in addition to the sanctions in place and targeted towards Russia and the occupied Donetsk and Luhansk regions.

For more detailed information on particular clients, corporate entities or private individuals you can contact Nathan Pinhasov from GrECo Group Legal, n.pinhasov@greco.services, or Andreas Krebs from GrECo Group Insurance Mediation Services, a.krebs@greco.services.

Sanctions against private individuals

IEU sanctions prohibit any direct or indirect economic interactions (prohibition of payment and provision of services) with listed persons, as well as with all companies in which a listed legal entity or natural person has an ownership interest of 50% or more.

In addition, this applies to companies controlled directly or indirectly by sanctioned persons or to those where these persons may exercise a dominant influence.

The list of persons against whom financial actions apply was extended several times by Executive Order 2022/260 (listing 21 natural persons, two banks and one company) and Executive Order 2022/261 (listing 335 Duma deputies) of 23. February 2022, as well as on February 25 with Decree 2022/332, against 99 additional natural persons, including No. 670 Russian Foreign Minister Sergey Lavrov as well as No. 699 Russian President Vladimir Putin.

The following activities are examples of EU’s prohibition on payment and provision of services:

  • Transfers of funds
  • Sale of goods
  • Provision of services
  • Management of assets
  • Provision of other economic resources, e.g.: Cash, checks, monetary claims, Deposits with financial institutions, Publicly and privately traded securities and debt instruments including: Stocks and shares, Interest, dividends, or other income, Loans, guarantees, Bank guarantees, Documents containing indicia of participation in funds, etc.

Sanctions against Legal Entities

In addition to natural persons, selected legal entities have also been sanctioned by the EU. These sanctions – analogous to the sanctions for natural persons – prohibit direct or indirect economic interaction in the form of a prohibition on payment and provision of services (see non exhaustive list above). The assets of the listed legal entities in the EU will be frozen.

  • Several Russian banks are excluded from the international payment system SWIFT. All those already sanctioned in the past are affected by said SWIFT exclusion. Further financial institutions and banks could be excluded from SWIFT.
  • Ban on transactions with and freezing of the Russian Central Bank’s assets within the EU and G7 countries, no more transactions possible within the EU.
  • European airspace ban on Russian aircraft.
  • Media companies such as Sputnik, Russia Today and their subsidiaries are restricted in their activities in the EU.
  • Sanctions against Belarus: EU import ban on Belarusian products such as minerals fuels, tobacco, wood, cement, iron and steel, and personal sanctions.

Sectoral Sanctions

  • Military goods embargo: The direct/indirect export, supply, sale of military equipment and other defense material to Russia is prohibited. Also prohibited are technical assistance and brokering services, as well as financing the supply.
  • Export ban for dual use goods: Prohibited direct/indirect supply/export/sale of listed dual use items (Annex I of Dual Use Regulation 2022/328), irrespective of their civilian or military use, with or without origin in the Union. Dual use goods are designed or suitable for both civilian and military purposes.
  • Prohibition of payment, provision of services and direct/indirect supply/export/sale of goods and technology different from listed dual use items: General electronics, computers/electronic assemblies, telecommunications and information security, sensors and lasers, navigation and avionics, marine and aeronautical, and space and propulsion equipment therefor with technical performance capabilities different from listed dual use items.
  • Export ban on certain oil equipment goods: The indirect/direct supply/export/sale of goods and technology, whether originating in the Union or not, which can be used for oil refining, directly or indirectly to or for use in Russia shall be prohibited. The prohibition also applies to technical assistance, brokering services, and financing or financial assistance related thereto, whether directly or indirectly.
  • Export ban on aircraft and spacecraft, parts thereof, and technical and financial assistance and (re)insurance related thereto.
  • Extensive Restrictions of the EU capital market: For instance, the exclusion of certain Russian banks and military and oil industry companies from EU capital market.

In addition to the previous prohibitions on buying, selling, brokering, providing investment services or ancillary services, directly or indirectly, transferable securities and money market instruments with a maturity of more than 30 days from Russian banks listed in Annex III to Regulation 833/2014 (SBER Bank, VTB Bank, VEB Bank, GAZPROM Bank, ROSSELKHOZ Bank), on or after 12 April 2022, also applicable to Alfa Bank, Bank Otkritie, Bank Rossiya and Promsvyazbank), as well as for Russian companies in the military and oil industries (Almaz-Antey Kamaz Sea Trading Port, Novorossiysk Rostec, Russian Railways, JSC PO Sevmash Sovcomflot and United Shipbuilding Corporation).

Regional Sanctions in Ukraine

Sanctions in relation to Crimea and Sevastopol
Import ban on goods originating in Crimea or Sevastopol effective from June 2014: the EU prohibits the import of all goods originating in Crimea or Sevastopol and financing and insurance/reinsurance related to them.

As of December 20, 2014, further prohibition applies on export of certain goods and technology listed in Regulation 692/2014 Annex II to natural or legal persons, entities or bodies in Crimea or Sevastopol or for use therein. Similarly, the sale, supply, transfer of these goods and related direct or indirect technical assistance, brokering services, financing are prohibited.

Sanctions against the Donetsk and Luhansk regions and in response to the deployment of Russian forces to the regions

Further questions?
The CC Credit Team will be happy to answer any specific questions you may have about your trade credit insurance contract. Please contact us directly.

  • Ban on Import: The import of goods originating in the Donetsk and Luhansk regions not controlled by the Ukrainian government is prohibited as of February 24, 2022. It is also prohibited to provide, directly or indirectly, financing or financial assistance, as well as insurance and reinsurance, for the import of these goods. The prohibition does not apply to goods originating in these territories, if the goods are provided to and have been inspected by the Ukrainian authorities and a certificate of origin has been issued by the Ukrainian government.
  • Ban on new investments: Prohibited from acquiring real estate, facilities, securities of a participating nature, or shares in the foregoing, or expanding existing investments thereof. Prohibited from providing financing to entities, establishing joint ventures with entities, and providing investment services thereto in the non-Government-controlled Donetsk and Luhansk Oblasts.
  • Export ban on goods in the fields of transport, telecommunications, energy, prospecting, exploration and extraction of oil, gas and mineral resources
  • Prohibition on provision of technical assistance or intermediary services, construction or engineering services for infrastructure: The competent national authorities (in Austria: BMEIA) may, by way of derogation from the above prohibitions on new investment, export of goods and provision of technical and financial assistance, make exceptions for humanitarian reasons or to ensure the security of existing infrastructure.
  • Tourism activities: Prohibition on providing services directly related to tourism activities in the occupied Donetsk and Luhansk regions.

Please note that this information has been compiled based on the sanction regime valid from week 09, 2022, and that there may be amendments at any time when the crisis worsens. We will keep you updated on further developments.

The article is written by Andreas Krebs.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

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Property damage caused by war on land – aspects regarding insurance cover

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It is a principle of insurance that due to the potential accumulation of claims there is a general exclusion of damage caused to a risk (buildings, factories, their technical equipment, installations, stocks and other contents) in connection with war and civil war.

In this information and in oncoming postings we will focus on the question what actions of war as we see them currently in Ukraine mean for the existence of insurance coverage and for payments of damages by the insurer. We start with the most important part, considering the values involved, property insurance and property business interruption (BI).

Exclusion and termination of cover

It is a principle of insurance that due to the potential accumulation of claims there is a general exclusion of damage caused to a risk (buildings, factories, their technical equipment, installations, stocks and other contents) in connection with war and civil war. The standard definition of this exclusion is “exclusion of damage caused as direct or indirect consequence of any kind of military action, with or without declaration of war, and all violent actions by states; further caused by civil commotion, uproar, rebellion, revolution, civil war including all military or police or other state measures in connection therewith.”

Standard European insurance wordings do not automatically terminate insurance contracts if the situation described by the exclusion quoted occurs. Quite on the contrary, they state clearly that cover remains in existence, but the insured has to prove that a fire occurred during war time does not have its origin in war or any military action.
There are insurance contracts, however, that terminate cover at the outbreak of war, so it is important to have a look in the standard or written wordings applicable to each individual insurance contract.

Most reinsurance treaties still have the World War clause, saying that the treaty ends in the case of a war between the nations United States, Russia, United Kingdom, France and China. So, the extension of the current conflict into a war between Russia and NATO would most probably trigger this clause. But we are not there, and we can only hope that we never will.

Grey area sabotage, arson and terrorism

War and warlike action, the breakdown of public order may lead to loss events, like damage due to sabotage, arson committed by persons inside and outside a company, acts of terrorism. Here we enter a certain grey area, as far as insurance coverage is concerned. Each claim will obviously be analyzed very carefully whether it is a case of indirect consequence of the war, as defined above, or whether the property damage occurred independently from the conflict situation.

Another point to be considered is that the insured must in fact own the premises insured at the time when the loss occurs. Any change in this ownership, such as seizure or requisition – not insured in property insurance, as this is a political risk – but also abandonment of or being chased from premises will most probably suspend coverage. If the ownership is still existing as a title, but no employees are left on the premises, this means that the control of the risk has been given up and the usual obligations of the insured cannot be fulfilled any longer, which causes serious doubts regarding the validity of cover.

Non-Property Damage Business Interruption

These principles in respect of property insurance apply equally to business interruption. Even if a Non-Property Damage Business Interruption endorsement has been agreed, this follows the basic and general conditions of BI. So, in the case of an enterprise standstill due to the lack of energy supply, cut of ways of communication, disruption of the supply chain, lack of workforce etc. there will always be an evaluation whether these events are due to a situation of war or not.

Although the margin for negotiation is rather small for a broker in this context, GrECo will do the same as in every other loss event, that is to support the interests of our clients in order to reach a fair and just evaluation of the insured’s claim and to obtain wherever possible a correct loss payment from the insurers.

The article is written by Andreas Krebs.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

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GrECo Group Task Force Ukraine conflict – statement on sanctions and insurance

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The conflict between Russia and Ukraine and the threat of heavy sanctions to be imposed by the Western world as consequence of Russian military action, have brought the topic of financial sanctions and the position of insurance again into the focus of consideration.

In view of the rapid developments in the conflict between Russia and Ukraine and military action started on Ukraine territory, GrECo Holding has set up a Task Force responsible for gathering all information on the current crisis and for reactions in all fields of our activities. Starting with today, we will provide information on all topics and developments linked with the situation on our website for the information of clients and partners. In this we will be supported by our colleagues in the countries concerned and information will also be based on statements obtained from insurers and reinsurers.

We are starting this reporting with the sanction topics. The next news will refer to what war and civil war mean to insurance contracts and coverages.

For all further information on sanctions please contact GrECo Group Legal, Nathan Pinhasov, n.pinhasov@greco.services For any information and questions regarding insurance matters please approach GrECo Group Insurance Mediation Services, Andreas Krebs, a.krebs@greco.services

International sanctions and insurance – general principles

The conflict between Russia and Ukraine and the threat of heavy sanctions to be imposed by the Western world as consequence of Russian military action, have brought the topic of financial sanctions and the position of insurance again into the focus of consideration. After sanctions imposed e.g. on Iran in 2012 or Russia in 2014 after the Crimea invasion, a lot of experience with this political instrument has been obtained and clarifications have been made, not at least by the European Union. It is important, therefore, to take another look onto this matter.

Sanctions by the EU

The European Union sees sanctions as a tool to prevent conflicts and to respond to crises, the intention being “to bring about a change in policy or activity by targeting non-EU countries, as well as entities and individuals, responsible for the malign behavior at stake.” Most of the sanctions are in accordance with United Nations resolutions and are also agreed with the United States and the United Kingdom.

Some of the sanctions are published as Guidance notes to the governments of the Member States, but in some severe cases they are issued as Regulation, thus coming into force immediately in all Member States and prohibiting trade or financial transactions with states or persons against which the sanctions are directed. It is forbidden to each EU citizen, company or institution to violate this regulation by any way, and normally the decision is enforced by high penalties.

Although this kind of sanction does not only prevent the conclusion of new contracts it also interferes with existing contracts and, especially important for insurance contracts, prevents for instance the payment of claims. This situation is reflected by exclusions in insurance contracts with the effect that coverage is terminated once the sanction becomes valid. As it is forbidden to insurers, reinsurers and brokers alike to neglect or circumvent this exclusion – for instance by trying to place a contract affected by the sanction in a market where the sanctions do not apply – it is really fundamental, to be compared only with the War or Nuclear exclusions.

Sanctions by Third countries

More difficult and complex is this issue, if the sanction is pronounced by a state outside the EU. There can be bilateral or multilateral sanctions between two or more states. Starting with Cuba, the United States have become very active in putting other states under sanctions. They do this with the same consequences as described for the EU: creation of a Federal Law with effect on all citizens and companies living or having their headquarters or having only assets as foreign owners (companies, capital, licenses and other titles) in the United States. They all risk penalties, seizing or freezing of capital etc., when acting contrary to the sanction act.

For this reason, all reinsurers and most internationally acting insurers have integrated the Sanction exclusion clause into their contracts with the same effect as described for EU sanctions above. This means that, even if an insurance contract has not anything to do with US legislation, cover will be excluded. It is true that the EU reacted on this with a so-called blocking statute, saying that “the extra-territorial application of laws adopted by third countries will not be recognized by the Union”. This has led to European insurers associations issuing own clauses, like in Austria, where it is stipulated that “exclusion from cover is valid if based on sanctions by the US or other third countries, if they are not against European or local law”.

Economic reality and fear of reprisals mean that globally acting reinsurers and insurers will obey US sanctions despite the political attitude of the EU or any Member State. But at least there is the possibility to look for insurance markets not intimidated by US law who may grant cover.

Scope of sanctions

Originally, sanctions were imposed on whole countries, since it was difficult or impossible to separate government interests from that of economic entities of the country concerned (e.g. Cuba, North Korea, Libya). Nowadays, (financial) sanctions have become more sophisticated and detailed. They are directed against persons with political, military or economic functions in that state, against certain industries, institutions and firms. This has led to establishing sanction lists to be checked in the moment when a business relationship is intended or when delivery of goods or financial transactions have to be prepared. For EU sanctions, a Sanction map (Sanctionsmap) has been installed, which is openly accessible, and most states have their own sanction lists to be consulted.

Embargoes

The embargo is the older parent of the financial sanction, having its roots in sea blockades of long times past. It means the prohibition of trade and transport of certain goods to given destinations. Most common are arms embargoes, but they can be extended to all kinds of goods, in most cases still to those that might be used for weapon production or directly for military use. Goods falling under an embargo ruling cannot be insured. Any circumvention by false declaration of the nature of goods or by sending them to third countries that forward the goods to the sanctioned destination will be prosecuted and providing of insurance may be considered as a criminal act. Therefore, insurers will have a close look on shipments, export declarations and the like.

Exemption to sanctions for humanitarian reasons

As we have seen, sanctions disrupt the insurance cover since no further financial transaction is possible. This affects, for instance, construction or erection projects in the country concerned or the operation of a local factory, especially in the case that the sanction is extended to the whole country. If a loss happens where it is necessary and even urgent to send money or relief goods to persons affected by the loss event (accidents of employees, fire, natural catastrophes), the humanitarian aspect may come into consideration. The EU has made clear that it is prepared to make exemptions to sanctions for humanitarian reasons, since the population of a country shall not be punished when its government is under sanction for the afore-mentioned malign behavior. In such cases, applications can be made to the relevant authorities with the aim to allow financial transactions for specific situations.

The role of GrECo as insurance broker and consultant

As this whole sanction topic is a very complex one, GrECo sees its role as insurance broker in the information of all clients with respect to insurance implications, under which circumstances cover can be obtained for countries or industrial sectors where sanctions have been imposed, what consequences there are for running contracts where the cover is stopped due to sanctions, which margin there exists discussing the cover with insurers. By no way, the broker may be ordered to assist in the circumvention of sanctions or embargoes.

In the insurance industry, sanctions have become part of compliance regulations and codes of business conduct. Insurers will, therefore, have a close look on the business offered to them with respect to sanctions, and – in international insurance – on the question where the business comes from, out of which country, who is the insurance buyer, who the insured. Major insurers are aware of the many individual aspects that sanctions may have, and they are prepared to make their decisions according to the situation in each single case.

GrECo will closely monitor all sanctions now imposed by the European Union, the United Nations, the United States and the United Kingdom on Russia in order to be prepared to give thorough advice on the consequences on insurance and insurance payment transactions in this new situation.
We will post further news on sanctions on Russia, once the full scope of them and their implications will be known.

The article is written by Andreas Krebs.

Paul Spittau

Head of Group Carrier Relations & Insurance Mediation

T +43 664 537 17 42

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