Maritime Mutual Re-Insurance Wind Down General Licence
Summary
The UK Treasury has issued a General Licence allowing UK Insurers and Insurance Brokers to process funds related to Maritime Mutual Re-Insurance wind-down activities. This licence is granted under the Russia (Sanctions) (EU Exit) Regulations 2019 and permits transactions for contracts agreed prior to February 24, 2026.
What changed
This General Licence, issued under the Russia (Sanctions) (EU Exit) Regulations 2019, provides specific permissions for UK Insurers, UK Insurance Brokers, and Relevant UK Institutions to engage in activities necessary for the wind-down of Maritime Mutual Re-Insurance. It exempts certain actions from prohibitions in regulations 11-15 of the Russia Regulations, specifically allowing the receipt, processing, and transmission of funds or economic resources to or from Maritime Mutual Association Limited (Gibraltar), Maritime Mutual Insurance Association (NZ) Limited, and their subsidiaries. These permissions are contingent on insurance or reinsurance contracts being agreed in writing prior to February 24, 2026, and are valid until the licence's expiry date.
Regulated entities must maintain accurate records of any activity conducted under this licence for a minimum of six years. The licence aims to facilitate an orderly wind-down of Maritime Mutual Re-Insurance while ensuring continued compliance with sanctions regulations. While the licence itself does not impose new sanctions, it provides a framework for specific, permitted transactions that would otherwise be prohibited, thereby requiring careful review by compliance teams to ensure adherence to all conditions and record-keeping requirements.
What to do next
- Review the conditions and permissions outlined in the General Licence INT/2026/8893924.
- Ensure all transactions related to Maritime Mutual Re-Insurance wind-down activities comply with the licence terms, particularly regarding contracts agreed before February 24, 2026.
- Maintain accurate and complete records of all permitted activities for a minimum of six years.
Source document (simplified)
GENERAL LICE NCE – Maritime Mutual Re-I nsurance Wind Down Gen eral Li cence INT/2026/8 893924 1. This lic ence is granted un der regulation 64 of the Russia (Sa nctions) (EU Exit) Regul ations 2019 (“the Russia Re gulations”). 2. Any ac t which wou ld otherwise breach the prohibitions in regulations 11 to 15 of the Russia Regulations is exempt from those prohibitions to the extent required to give effect to the permissions in thi s licence. 3. In this licenc e: The “DP” or “ DP s ” means Maritime Mutual Association Limited (“Marit ime Mutua l Gibraltar”); Maritime Mutu al Insuran ce Association (NZ) Limited (“Maritime Mutu al NZ”) and their subs idiaries. A “ Subsidiary ” m eans Any entity inc orporated a nywhere in the world ow ned or controlled, direc tly or indire ctly, by Mari time Mutual Gibraltar and/or Maritime Mutua l NZ pursuant to regulation 7 of the Russia Regulations. A “Designated P erson” means Any individual or a body of persons (corpora te or unincorporate) designated un der regulation 5 of the Russia Regulations an d/or an y individual or body of persons (corporate or unincorporate) owned or controlled directly or indire ctly by that designated person within the me aning of re gulation 7 of the Russia Regulations. A “ Person ” means An individual or a body of persons (corporate or unincorporate) but does not inc lude a Designated Person. “UK Insurer” mean s A firm with permissi on to effect or carry out con tracts of insurance or reinsuranc e in the UK and registe red by the Financial Con duct Authority (FCA). “UK Insurance Br oker” Means A firm carrying on insurance distribution activit y in the UK as an intermediary betwee n a UK Re-insure r and the DP and registered by the Finan cial Conduct Autho rity (FCA) A “ Relevant UK Institution ” means A person that ha s permission un der Part 4A of the Financial Se rvices and Ma rkets Act 2000 (perm ission to carry on regulated ac tivity). A person that is au thoris ed or registered under Part 2 of the Payment Service s Regulations (S I 2017/752). A person that is au thoris ed or registered under Part 2 of the Electronic Money Regulations (SI 2011/99). A person that is a “recognised clearing h ouse”, “th ird country central c ounterparty”, “recognised CSD ” or
“third country CSD ” for th e purposes of s.28 5 of the Financial Se rvices and Ma rkets Act 2000. A person that is an opera to r of a recognise d paymen t system (or that is a service provider in relation to recognised paymen t systems) f or the purposes of Part 5 of the Banking Act 2009. Permissions 4. Under this licence, subject to the conditions below, and until the date of expiry of this licence: 4.1 A UK Insurer and/or a UK Insuranc e Broker may receive, process and /or transmit funds or economi c resourc es to or fr om the DP or DPs, where they are obligated to do so unde r insurance or reinsuranc e contracts agreed in wri ting prior to 24 February 2026. 4. 2. A UK Insurer and/or a UK Insuranc e Broker may receive, process and/or transmit funds or economic resourc es to or from the DP or DPs, in order to cancel and/or terminate and/or extricate themselves from any insurance or reinsurance contracts agreed in writing prior to 24 February 2026. 4.3. A UK Insurer, UK Insuran ce Broker, Relevant UK Ins titution and/or a Person to ef fect the permission s at paragraphs 4.1 an d 4.2, may carry out any acti vity reason ably necessary to that end. 4. 4 A Rele vant UK Institu tion may process payments made in ac cordance with paragraph s 4.1 to 4. 3 above. Record-keepin g Requiremen ts 5. A Person conducting activity under this licen ce must keep accurate, complete and readable records, on paper or elect ronically, of any activity purporting to have been pe rmitted under this licence for a m inimum of 6 years. General 6. The permissions in this licen ce do not authorise any act which will result in a breach of any part of the Russia Regulations, save as permitted under this or other li cences granted under the Russia Regulations. 7. Information provided to HM Treasury in connection with this licence shall be disclosed to third parties only in complianc e with the UK General Data Protection Regulation and the Data Protection Ac t 2018. 8. This licence takes e ffect from 24 February 2026 a nd expires at 23:59 on 09 April 2026. 9. HM Treasury ma y vary, revoke or su spend this licence at any time.
Signed: Office of Finan cial Sanctions Implementation HM Treasury 24 February 2 026.
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