Circular: “General Trade Licence”: Reporting of ships calling at Russia or passing through Russian waters

The war in Ukraine has led to various changes being adopted regarding British sanctions against Russia. On 17 March, the UK Government published a ‘General Trade Licence’ to clarify these sanctions. A copy of the General Trade Licence can be found at the following link:
https://www.gov.uk/government/publications/general-trade-licence-russia-sanctions-vessels

This licence makes clear to insurers and reinsurers in which cases they are still allowed to insure ships that sail through Russian waters and/or in Russian ports. There is therefore no question (at the moment) of a total ban on sailing to Russia. However, an obligation to report has been introduced for the purposes of monitoring compliance with sanctions. All insurers and reinsurers operating from the UK have to store information about journeys made and must notify the UK Secretary of State where that data will then be stored for five years.

This reporting obligation came into effect on the same date that the General Trade Licence was published, 17 March 2022. Failure to comply with this reporting requirement may have consequences for the insurance of the ships concerned and the payment of any claims. Through this letter, we would therefore like to urge our members and insured parties who have been in Russia since 17 March 2022 to send us the following information:

1. Name of the Russian ports visited
2. Name of the vessel
3. IMO number of the vessel
4. Type and quantity of cargo
5. Start and end dates of the voyage
6. Name of the vessel’s owner
7. Name of the vessel’s charterer
8. Name and address of the shipper/supplier
9. Name and address of the recipient
10. Name and address of the purchaser (if known and not the same as the recipient)
11. Copy of the bill of lading (if present)

The attached template can be used to facilitate the process. The completed file can then be sent together with copies of the bills of lading to underwriting@nnpc.nl.

Finally, we would like to emphasize once again that trade with Russia is currently subject to severe restrictions and that trade in contravention of the sanctions that have been imposed is not covered. As stated in previous news reports, it is therefore still important that you, as a member or insured party, carry out the necessary due diligence yourself. If you have any questions about this, we will be happy to assist.