Sectoral sanctions
Sanctions that prohibit certain transactions with an entity, such as long-term financing, without freezing its assets: the entity remains a lawful counterparty for everything else.
Sectoral sanctions target sectors of an economy, finance, energy or defense, and prohibit only certain categories of transactions with the designated entities, instead of freezing all their assets. The United States introduced them against Russia in July 2014, with a list separate from the SDN list, and the European Union adopted them on July 31, 2014 through Regulation 833/2014. Their difficulty lies in that half measure: the same company is a lawful customer for one contract and a prohibited one for another, depending on the length of a loan or the nature of a good. For insurance, this means screening by name is no longer enough; the insured transaction itself must be qualified. It is also through this regulation that the Union banned in 2022 the insurance of certain Russian goods and shipments, which makes it a text the underwriter rereads with every sanctions package.
On July 16, 2014, OFAC placed Rosneft, Novatek, Gazprombank and VEB on the new sectoral list: their accounts were not frozen and their oil still sold, but lending to them for more than 90 days became prohibited for US persons.
SSI list, Sectoral Sanctions Identifications List, sectoral sanctions
Follow the research
One letter a week. First, the week's underwriting note, when one is published: a dated, argued decision, signed by Paul Bernardski. Then what the observatory published on cyber risk, political risk and insurance. No account, no tracking.
No spam, one-click unsubscribe, no data ever sold.