Notice - Compliance with International Sanctions and Data Call – Insurance Groups and Class 4, 3B, 3A, C, D and E Insurers (2022-04-18)

Summary

This BMA notice reminds Bermuda insurance groups and Class 4, 3B, 3A, C, D and E insurers of their obligation to comply with international sanctions and requires them to complete a one off data call on their exposure to the Russia Ukraine conflict.

• Sanctions compliance: Registrants must ensure they comply with all applicable laws, including the International Sanctions Regulations 2013 and additional sanctions imposed over the Russia Ukraine conflict, as part of the minimum criteria for registration under the Insurance Act 1978.
• Annual filing attestation: Registrants must confirm compliance with the minimum criteria for registration, including sanctions compliance, as part of their annual filings, and report sanctions exposure on the Schedule of Sanctions enclosed with the annual filing.
• Special data call: Insurance groups and Class 3A, 3B, 4, C, D and E insurers must complete the Exposure to International Sanctions data call, disclosing exposure to the Russia Ukraine events and their impact on assets and underwriting as at 31 March 2022.
• Submission method: Data call responses must be emailed to RiskAnalytics@bma.bm by 31 May 2022; groups reporting for multiple entities must list registration numbers and company names in section 1 of the data call.

The notice is informational and reiterative of existing legal obligations, but it also imposes a specific new one off reporting deadline for the sanctions exposure data call.

Key obligations

• Registrants must maintain processes and internal controls to manage compliance with international sanctions, including the International Sanctions Regulations 2013 and sanctions related to the Russia Ukraine conflict.
• Registrants must confirm compliance with the minimum criteria for registration (including sanctions compliance) as part of their annual filings under Section 15A of the Insurance Act 1978.
• Registrants must report exposure to international sanctions on the Schedule of Sanctions enclosed with the annual filing.
• Bermuda insurance groups and Class 3A, 3B, 4, C, D and E insurers must complete and submit the Exposure to International Sanctions data call as at 31 March 2022 to RiskAnalytics@bma.bm by 31 May 2022.
• When submitting on behalf of multiple entities within an insurance group, registrants must provide registration numbers and company names in section 1 of the data call.

Applies to

Insurance groups, Class 4 insurers, Class 3B insurers, Class 3A insurers, Class C insurers, Class D insurers, Class E insurers

Deadlines

• 31 May 2022: Deadline to submit the Exposure to International Sanctions data call (covering exposure as at 31 March 2022) via email to RiskAnalytics@bma.bm.