(1) American International Group UK Limited (2) (As Transferee of AIG Europe Limited) (3) Markel Syndicate Management Limited (4) Talbot Underwriting Limited (4) Berkshire Hathaway International Insurance Ltd (5) Liberty Mutual Insurance Europe SE (6) ANV Corporate Name Limited (7) Arch Insurance (UK) Limited v Qatar Insurance Co. (Branch of a Foreign Company) [2024] DIFC CA 008 (20 September 2024)

(1) American International Group UK Limited (2) (As Transferee of AIG Europe Limited) (3) Markel Syndicate Management Limited (4) Talbot Underwriting Limited (4) Berkshire Hathaway International Insurance Ltd (5) Liberty Mutual Insurance Europe SE (6) ANV Corporate Name Limited (7) Arch Insurance (UK) Limited v Qatar Insurance Co. (Branch of a Foreign Company) [2024] DIFC CA 008 (20 September 2024)

The Court held that the Sanctions Clause does not void the entirety of cover but only to the extent that payment or provision of cover would expose the reinsurer to sanctions. On the facts, the only beneficiaries of the reinsurance contracts are the Insurer and the Bank, not Alpine or the Iranian nationals. Payment under the contracts does not constitute a prohibited indirect supply of insurance services to Iran under US law. The appeal fails as the Judge correctly applied the law and facts.

Citation
[2024] DIFC CA 008
Parties
Claimant/appellant: American International Group UK Limited; Claimant/appellant: Markel Syndicate Management Limited; Claimant/appellant: Talbot Underwriting Limited; Claimant/appellant: Berkshire Hathaway International Insurance Ltd; Claimant/appellant: Liberty Mutual Insurance Europe SE; Claimant/appellant: ANV Corporate Name Limited; Claimant/appellant: Arch Insurance (UK) Limited; Defendant/respondent: Qatar Insurance Co. (Branch of a Foreign Company)
Jurisdiction
United Arab Emirates
Judgment Date
20 September 2024
Procedural Posture
Appeal / Judgment on Appeal After Trial and Counterclaim
Outcome
Appeal dismissed
Legal Topics
Sanctions Clauses, Reinsurance Liability, US Sanctions Compliance, Interpretation of Insurance Contracts

Case Brief

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Parties

American International Group UK Limited

Claimant/appellant

Markel Syndicate Management Limited

Claimant/appellant

Talbot Underwriting Limited

Claimant/appellant

Berkshire Hathaway International Insurance Ltd

Claimant/appellant

Liberty Mutual Insurance Europe SE

Claimant/appellant

ANV Corporate Name Limited

Claimant/appellant

Arch Insurance (UK) Limited

Claimant/appellant

Qatar Insurance Co. (Branch of a Foreign Company)

Defendant/respondent

Procedural Posture

Appeal / Judgment on Appeal After Trial and Counterclaim

  1. 1 Whether US sanctions prohibit payment under reinsurance contracts where the underlying beneficiary is indirectly owned by Iranian nationals
  2. 2 Proper interpretation and scope of the Sanctions Limitation & Exclusion Clause in reinsurance contracts
  3. 3 Whether provision of cover or payment constitutes indirect supply of insurance services to Iran under US law

Ratio Decidendi

The Court held that the Sanctions Clause does not void the entirety of cover but only to the extent that payment or provision of cover would expose the reinsurer to sanctions. On the facts, the only beneficiaries of the reinsurance contracts are the Insurer and the Bank, not Alpine or the Iranian nationals. Payment under the contracts does not constitute a prohibited indirect supply of insurance services to Iran under US law. The appeal fails as the Judge correctly applied the law and facts.

Court Disposition

Appeal dismissed

Orders

  • Stay of Judgment on the Counterclaim discharged
  • Appellants to pay costs of the Application to Respondent on standard basis, subject to immediate assessment