The Danish Financial Supervisory Authority has published the results of a thematic review of how a group of non-life insurers manage and control compliance with EU sanctions against Russia under Council Regulation (EU) No 833/2014. Based on the firms’ responses, the authority assesses that the insurers reviewed are focused on sanctions compliance and it did not identify issues warranting supervisory action. The review covered eight insurers and looked in particular at potential insurance of the so-called shadow fleet and the heightened risk of sanctions circumvention through complex ownership structures or intermediaries. Some firms reported having only Danish customers or no shipping-sector customers, while others have international activities; firms described ongoing work to ensure compliance, including screening and controls, and were asked whether they had rejected approaches from shipping customers because an agreement would or could conflict with EU sanctions. The Danish Financial Supervisory Authority plans to maintain a strong supervisory focus on compliance with Russia-related sanctions, including how firms update procedures in response to developments in the threat landscape and international sanctions regimes, and expects compliance functions to actively monitor adherence.
Danish Finanstilsynet 2025-12-10
Danish Financial Supervisory Authority thematic review finds non-life insurers focused on complying with EU sanctions against Russia
The Danish Financial Supervisory Authority's review of eight non-life insurers found no compliance issues with EU sanctions against Russia. It highlighted efforts to manage sanctions, especially concerning the shadow fleet and complex ownership. The authority will continue focusing on sanctions compliance and expects firms to actively update procedures in response to evolving threats and sanctions regimes.