Sanctions database

Exceptions in relation to aircraft and vessels for emergencies in certain cases, for authorised conduct and for purposes of national security or prevention of serious crime are applied.
The prohibitions are not contravened by the provision of insurance or reinsurance services, to the extent that such services are provided in connection with a qualifying removal (a removal of an aircraft or vessel from the UK to Russia in relation to which the conditions set out in paragraph (1) are met.
On 21 June, OFSI updated its guidance on this regulation and clarified that: “The prohibition would not apply where the insurance is for the benefit of the non-Russian owner of the items, rather than their user or operator. Nor does it apply where the items either remain in Russia as the result of the termination of a lease and against the lessor’s will; or are being flown out of Russia in the process of returning them to their owner”.
OFSI clarified that “the provision of insurance and reinsurance services in respect of a satellite where the only nexus with Russia is that it is orbiting over Russia, or broadcasting to Russia (and where the insurance and reinsurance services will not be provided to a person connected with Russia), would… not come within the scope of these prohibitions.”