Lloyd’s is committed to complying with the sanctions laws and regulations of the United Kingdom, European Union, the United Nations and the United States (the sanctions lists), as well as the applicable sanctions laws and regulations in the jurisdictions in which Lloyd’s operates. This position is taken in order to manage regulatory, legal, operational and liquidity risks, and takes in to account broader financial crime concerns.
Lloyd’s Financial Crime Policy prohibits or restricts dealing, directly or indirectly with parties subject to restrictive measures issued by these jurisdictions. Lloyd’s reserves the right to refuse to engage in business involving parties with links to the sanctions lists, even where permitted by applicable sanctions laws and regulations where these activities fall outside of Lloyd’s risk appetite. In some cases, this risk appetite may be stricter than our legal obligations.
Lloyd’s Financial Crime Policy prohibits or restricts, without limitation:
1. Engaging directly or indirectly with individuals or entities named on a sanctions list or entities owned or controlled by them;
2. Lloyd’s holding, via Funds at Lloyd’s (FAL), assets issued by individuals or entities named on a sanctions list or entities owned or controlled by them;
3. Engaging in business activities in, or with individuals or entities based in countries/regions subject to comprehensive sanctions.
Where business activity is considered outside of risk appetite, relationships or transactions may be declined or, in the case of FAL, assets will not be acceptable and alternatives will need to be provided.