Turkey's Request for Letters of P&I Cover

Turkey’s Ministry of Transport and Infrastructure, General Directorate of Maritime Affairs, has advised that from 1 December 2022, vessels transiting or entering Turkish waters must provide an insurance letter from the P&I companies stating the ship details, cargo and voyage and confirming that P&I insurance is valid and inclusive for the ship, voyage and cargo.

The Insurance Letter requirement from the P&I Companies

This letter must be added to the Sailing Plan 1 (SP-1) report while submitting to the Turkish authorities by ship agents and insurance companies. The letter must be sent by the insurance companies or their representatives.

If an illegal commercial act is made or prohibitions are violated prior to a liability giving rise to a loss, or in other cases such as these, damages will not be covered even if the ship has a valid P&I policy.

The International Group (IG Clubs) standing

A news circular issued by London P&I Club said that the International Group had assessed the situation and it had been agreed that Clubs ‘cannot and should not’ issue such a letter. It was noted that the Turkish Government’s requirements go well beyond the general information that is contained in a confirmation of entry letter. It requires a P&I Club to confirm that cover will not be prejudiced under any circumstances, including where there is a sanctions breach on the part of the assured, ‘whether knowingly and intentionally or unknowingly and unintentionally.’

According to the IG, issuing such a letter would expose a Club to a breach of sanctions under EU, UK and US law and as such the Clubs cannot comply with the Turkish Authority’s request.

The International Group says it has sought to resolve this issue through negotiation and that further talks with the Turkish Authorities are likely to take place soon. The International Group does highlight though that there is a grace period on oil cargoes from Russia loaded before 5 December which expires on 19 January.