Wind-Down Explanation of Decision

Consistent with section 1242(f) of the FY21 NDAA, the Department of State is
enclosing a wind-down certification with regard to the following support service
providers, insurers and reinsurers for the Nord Stream 2 pipeline project, together
with this “Explanation of Decision” for such certification, under PEESA, as
amended, without having made assessments as to sanctionability during the
reporting period:
AEGIS Managing Agency Limited submitted documentation on January 29, 2021
showing it engaged in wind-down efforts, namely by terminating reinsurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 29, 2021.
Arch Insurance (UK) Limited submitted documentation on January 29, 2021
showing it engaged in wind-down efforts, namely by terminating insurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 29, 2021.
Aspen Managing Agency Limited submitted documentation on February 11, 2021
showing it engaged in wind-down efforts, namely by terminating insurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 29, 2021.
AXA Group informed the Department of State on January 29, 2021 that it engaged
in wind-down efforts, namely by terminating insurance coverage for the Nord
Stream 2 pipeline project. Termination of its policies went into effect on January
29, 2021.
Baker Hughes submitted documentation on January 8, 2021 showing P&M
Netherlands B.V. (“P&M”), the Baker Hughes company under contract, engaged
in wind-down efforts, namely by terminating its contract for support services for
the Nord Stream 2 pipeline project. Baker Hughes submitted documentation that
P&M did not and will not perform any such services during the 30-day wind down
period, and that wind-down efforts are to be completed by February 28, 2021.
Baker Hughes followed up on February 18, 2021 to confirm wind down efforts
were on track and will be completed by February 28, 2021.
Beazley Furlonge Limited submitted documentation on February 9, 2021 showing
it engaged in wind-down efforts, namely by terminating insurance coverage for the
Nord Stream 2 pipeline project. Termination of its policies went into effect on
February 5, 2021, following January 28, 2021 discussions with internal
stakeholders on wind-down options. Although the termination was not completed
prior to January 31, 2021, Beazley Furlonge Limited’s representative was in
contact with the Department prior to January 31, and Beazley Furlonge took initial
steps to wind down prior to such date; we therefore determined that its actions
during the relevant period demonstrate good faith efforts to wind down.
Bilfinger submitted documentation on January 13, 2021 of its decision to wind-
down, namely by terminating support services for the Nord Stream 2 pipeline
project. Bilfinger submitted documentation that wind-down efforts began in
December 2020 and were to be completed by January 31, 2021.
Canopius Managing Agents Limited submitted documentation on January 30, 2021
showing it engaged in wind-down efforts, namely by terminating reinsurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 29, 2021.
Chaucer Syndicates Limited submitted documentation on January 29, 2021
showing it engaged in wind-down efforts, namely by terminating insurance and
reinsurance coverage for the Nord Stream 2 pipeline project. Termination of its
policies went into effect on January 29, 2021.
Chubb Underwriting Agencies Limited submitted documentation on January 29,
2021 showing it engaged in wind-down efforts, namely by terminating insurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 29, 2021.
DNV GL submitted documentation on January 11, 2021 showing its two entities
had engaged in wind-down efforts, namely by suspending its work prior to January
1, 2021 and subsequently terminating its contract for verification activities for the
Nord Stream 2 pipeline project. DNV GL submitted documentation that it was not
engaged in performing services during the 30-day wind down period and that wind
down efforts were to be completed by January 31, 2021.
Hiscox Syndicates Limited submitted documentation on February 1, 2021 showing
it engaged in wind-down efforts, namely by suspending reinsurance coverage for
the Nord Stream 2 pipeline project. Suspension of its policies went into effect on
January 29, 2021.
Markel Syndicate Management Limited submitted documentation on January 30,
2021 showing it engaged in wind-down efforts, namely by terminating insurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 29, 2021.
MS Amlin Underwriting Limited submitted documentation on January 30, 2021
showing it engaged in wind-down efforts, namely by terminating insurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 30, 2021.
Munich Re Syndicate Limited submitted documentation on February 1, 2021
showing it engaged in wind-down efforts, namely by terminating reinsurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 30, 2021.
Tokio Marine Kiln Syndicates Limited submitted documentation on January 30,
2021 showing it engaged in wind-down efforts, namely by terminating reinsurance
coverage for the Nord Stream 2 pipeline project. Termination of its policies went
into effect on January 29, 2021.
Travelers Syndicate Management Limited submitted documentation on February
12, 2021 showing it engaged in wind-down efforts, namely by terminating
insurance and reinsurance coverage for the Nord Stream 2 pipeline project.
Termination of its policies went into effect on January 29, 2021.
Zurich Insurance Group submitted documentation on January 15, 2021 showing it
engaged in wind-down efforts, namely by terminating insurance coverage for the
Nord Stream 2 pipeline project. Termination of the policies went into effect on
January 18, 2021.