The Society of Lloyd’s has published a market bulletin (Y4861) in order to provide the market with guidance on developing appropriate and risk-based systems and controls to comply with international sanctions.

The guidance is split into three parts, which cover:

Compliance –

1. the guidance on compliance is aimed at Lloyd’s managing agents to assist them in assessing the adequacy of their own sanctions systems and controls.
2. The guidance is intended to assist managing agents with establishing appropriate systems and controls in respect of international financial and trade sanctions.
3. The guidance sets out considerations that should form the basis of an effective sanctions compliance framework.
4. The guidance covers risk assessment, governance, policies and procedures, sanctions screening, other screening and due diligence considerations, monitoring and reporting, record keeping and communications and training;

Delegated authorities –

1. the guidance is aimed at all managing agents who underwrite business using delegated authorities.
2. The guidance is intended to assist managing agents in establishing appropriate systems and controls relating to their cover-holders to ensure compliance with applicable sanctions and regulatory requirements.
3. The guidance focuses on governance, risk assessment of cover-holders, due diligence of new cover-holders, sanctions screening by cover-holders, sanctions clauses, training and audits; and

Claims –

1. the guidance is aimed at compliance managers who will need to ensure their claims team has appropriate sanctions procedures in place.
2. The guidance is intended to assist managing agents by outlining factors that should be considered in respect of their claims handling operations in order to meet legal and regulatory standards.

A copy of the market bulletin is available. http://bit.ly/1Aegqnv