Sanctions & Trade Controls
Where a transaction, a claim or an incident touches a sanctioned jurisdiction or party, Solaris Legal advises on the exposure. It acts for Indian insurers, overseas reinsurers and policyholders where a counterparty, vessel, cargo, payment route or beneficial owner is designated, or becomes designated mid-transaction. The same questions arise across the firm's insurance and reinsurance, cyber incident and regulatory work.
The legal framework
The measures principally engaged are those administered by the Office of Foreign Assets Control in the United States, United Nations Security Council measures as given effect in India, and European Union and United Kingdom restrictive measures where they reach the counterparty, the currency or the reinsurance market concerned. Domestically, the Foreign Exchange Management Act 1999, the Prevention of Money Laundering Act 2002 and the standards of the Financial Action Task Force bear on what banks, insurers and intermediaries will process. Contested matters come before Indian courts, consumer commissions and arbitral tribunals, at times with cross-border reinsurer involvement.
Scope
Exposure assessment where a counterparty, vessel, cargo, payment route or beneficial owner is designated, or becomes designated mid-transaction.
Consignments of goods contracted before designation, including questions of performance, delay, diversion and abandonment.
United States secondary sanctions exposure in the maintenance of marine cargo cover and the settlement of claims on consignments contracted before a supplier's designation.
Insurance and reinsurance of sanctioned or sanction-adjacent risks, including the effect of designation on cover, claims handling and payment.
Kidnap and ransom, political risk and sanctions issues in conflict and politically sensitive zones, including North Africa, Syria, Yemen, Afghanistan, Myanmar and North Korea.
Coverage for payments made on account of kidnappings by proscribed groups, including kidnappings in the course of vessel hijackings, and the concerns such payments raise with reinsurers.
Ransomware and extortion payments, including whether a payment can lawfully be made and what follows if the recipient is a designated or proscribed group.
Contractual protection, including sanctions clauses, conditions precedent, termination rights and force majeure analysis.
Counterparty screening frameworks and the conduct of internal reviews where a listing is discovered after the fact.
Writing on this subject
Hormuz in Crisis: What the US–Iran Conflict Means for Insurers, Reinsurers and Insureds in India
Maya Ramesh, Anmol Dhindsa · Mondaq · 15 June 2026