terrorist attacks through the use of motor vehicles in ...3f9290a5-6c14-4a68...general rule under...

Terrorist attacks through the use of motor vehicles inselected European countries

Swiss Re Terrorist attacks through the use of motor vehicles in selected European countries 1

Introduction

The latest terrorist attacks involving motor vehicles in many countries have dramatically highlighted a vulnerability of our society which can lead to a heavy toll of victims and to very large losses. The minimal planning and preparation work such acts require make them extremely difficult to anticipate and hence to counter with effective preventative measures.

To find answers to the crucial questions concerning the insurance industry’s potential exposure via Motor Third Party Liability (MTPL) covers, we have looked at the legal regulations in selected European countries in light of a likely scenario based on past experience.

2 Swiss Re Terrorist attacks through the use of motor vehicles in selected European countries

1 General considerations

The European road traffic is largely regulated by two sets of rules:

The Directive 2009/103/EC of the European Parliament and of the Council, that provides for compulsory motor vehicle insurance (Article 3) and a direct right of action against an insurance undertaking.

The Internal Regulations of the Council of Bureaux (basis for the Green Card System) that stipulate that claims shall be handled (by the correspondent) in conformity with any legal or regulatory provisions applicable in the country of accident relating to liability, compensation of injured parties and compulsory motor insurance.

In case of (mis-) use of a motor vehicle to intentionally injure or kill other people, once liability is established, one needs to distinguish between the question of indemnification of the victims (and their relatives) on the one hand, and the question of coverage for the Motor Third Party Liability (MTPL) on the other hand. The notion that the victims of motor vehicle accidents, and terrorist attacks, should be protected is pinned down in the Directive 2009/103/EC. This has led to two general approaches, which can be found in EU countries.

First, in some jurisdictions the MTPL insurer remains liable vis-à-vis the victims even if the driver of the motor vehicle acted intentionally. However, the driver does not have coverage for third party claims and may in principle face recourse claims by the MTPL insurer. The right of recourse is often of no value due to lack of financial means of the driver.

Second, some jurisdictions have generally exempted the MTPL insurer from liability for such cases, but have foreseen some other form of compensation through e.g. terror-pools, victims’ compensation funds, etc. to indemnify the victims of such attacks.

Accordingly, where there is no pool or fund covering the damage to victims of terrorist attacks committed by using a motor vehicle, it is likely that the MTPL insurer of the vehicle will be exposed; where there is such pool or fund, an exposure of the MTPL insurer may still be given through subrogation.


2 Guiding questions

In our analysis of the situation in selected European countries, we have tried to provide an answer to the question of whether or not a MTPL insurer can effectively exclude compensation for damage caused by an action with terrorist background involving a motor vehicle.

Within this framework the following has been considered:

coverage of bodily injury (and property damage)

the validity of policy exclusions vs protection of victims

the situation in which the driver has rented or stolen the vehicle

the situation in case of claims arising from domestic accidents vs accidents abroad or involving vehicles licensed abroad

the role of special indemnification bodies like terror-pools or victims’ compensation funds and subrogation

It should be noted that the conclusions highlight the question of a potential exposure for MTPL insurers, while governmental schemes or fund solutions are mentioned for the sake of completeness only, without addressing any further details. Although the general rule under Article 3 of the Convention of 4 May 1971 on the Law Applicable to Traffic Accidents provides that in the event of damage, the law applicable is the law of the country where the damage occurred, some of the respective legal issues remain undecided or the respective answers are unknown to us. Therefore, some of the conclusions are more of an indicative nature and do not represent a precise statement.


3 The country responses

3.1 Belgium

All policies for compulsory MTPL provide coverage for bodily injury and damage caused by terrorist acts since the Act of 1 April 2007 on insurance against losses caused by terrorism. As a consequence insurers/reinsurers and the Belgian authorities have founded a Terrorism Reinsurance and Insurance Pool (TRIP). The pool is financed by the insurance industry and the state, which contributes with a guarantee of EUR 300m to the total available funds of EUR 1bn per year. Therefore, any possibility given under Article 8 of the Terrestrial Insurance Contract Act (Loi sur le contrat d’assurance terrestre, 25.6.1992) to exclude policy coverage for intentional acts ought to be considered invalid in light of the Act of 1 April 2007.

For TRIP to be applicable, the vehicle must be registered in Belgium but the criminal act can occur abroad.

There is a State Compensation Fund for Intentional Acts of Violence in place from which victims, who would still be uncompensated if the TRIP means were exhausted, could claim indemnity. Compensation through this fund is of subsidiary nature only and is conditional on the perpetrator being unknown or insolvent.

3.2 France

Article L 113-1 (2) of the Insurance Code stipulates that the insurer shall not be responsible for loss or damage resulting from an intentional or fraudulent act of the insured. As this is considered as part of the “ordre public”, a French insurance policy cannot cover any act of terrorism which inherently is intentional. For that reason, the French MTPL insurance policies all contain an exclusion for intentional or fraudulent acts.

To ensure indemnification of victims of acts of terrorism for their bodily injuries, a special fund (FGTI, Fonds de Garantie des Victimes des Actes de Terrorisme et d’autres Infractions) was created in 1995. This fund indemnifies all victims of terrorist acts committed on French territory, French victims of terrorist acts committed abroad as well as the relatives of the previously mentioned victims. Subrogation against the MTPL insurer is not possible as the exclusion for intentional acts of any insured (policyholder, owner, keeper, driver, passenger) will apply.

In contrast, any motor, housing etc. insurance contract covering fire risks automatically grants cover for direct property damage caused by a terrorist act.

3.3 Germany

According to § 7 (1) of the German Road Traffic Act (RTA, Strassenverkehrsgesetz), the keeper of a motor vehicle is generally obliged to compensate an injured party for the damage caused through the use of the vehicle. But § 7 (3) of the RTA shifts the liability to the one who uses a motor vehicle without knowledge and authorization of the keeper, unless the keeper’s negligence allowed for the unauthorized use or the keeper has handed over the car to the driver (e.g. rental car), in which cases the keeper (and his MTPL insurer) remains responsible up to the maximum limit of liability of EUR 5m pursuant to § 12 RTA.

In the case that the keeper is also the offender (driver) the MTPL insurer is not liable based on § 103 of the Insurance Contract Act which excludes intentional and fraudulent acts. This is usually also stated in German MTPL policies. The exclusion also applies vis-à-vis injured third parties.

If the driver has used the vehicle without knowledge and intent of the keeper and there is no negligence of the keeper involved, neither the keeper [§ 7 (3) RTA] nor the MTPL insurer are liable.


Nevertheless, to cover the victims of intentionally caused accidents involving motor vehicles, the Compulsory Car Insurance Act (§ 12 (1) Pflichtversicherungsgesetz) provides that the Association for Victims of Road Accidents (Verein Verkehrsopferhilfe e.V.) steps in as National Fund and comes up for the losses of such affected third parties. However, the cover provided by the Fund is capped at an amount of EUR 7.5m per event, which corresponds to the minimum sum insured under compulsory MTPL insurance. Since, in the particular event of the Berlin Christmas market attack of 2016 involving a Polish transport company, the amounts of damage exhaust this cap, further indemnification might be sought from the general compensation scheme for victims of criminal offences and the federal fund of the Department of Justice for cases of hardship. Whether there can be any right of recourse of the Association for Victims of Road Accidents against the Polish MTPL insurer remains to be seen, but is doubtful, as the vehicle was taken against the will of the keeper and he is therefore not at fault (§ 7 (3) RTA). Under Polish law, the MTPL insurer would be liable for damage resulting from a terrorist act.

3.4 Italy

Some of the traffic law has found its way into the Italian Civil Code and MTPL is subject to specific strict regulations such as Article 2054, according to which the owner of the vehicle is jointly liable with the driver, unless he proves the vehicle was used against his will. Commonly MTPL policies do not have a specific exclusion ruling out “terrorism”, but as a general rule the Civil Code provides that damages caused “by intentional behaviors” cannot be covered by TPL policies. Although the exemption of coverage is stipulated in the law, court practice is different. Most of the courts consider in their awards that damages to third parties following accidents or crashes caused by intentional behaviors are covered by the MTPL policy, with a right of recourse of the insurer against the liable person.

It is, however, important to outline that in case of theft of a vehicle, the insurance cover ceases after a formal notification of theft is made by the insured to public authorities and communicated to the insurer. The cover expires after midnight of the day at which the notification is made (Decree no. 198 of 6 November 2007, Article 122 § 3). As a consequence, damages caused by occurrences happening after the coverage has lapsed will be compensated by the Italian Motor Guarantee Fund, including bodily injury claims.

3.5 Poland

The Act of 22 May 2003 on compulsory insurance, the Insurance Guarantee Fund and the Polish Motor Insurers’ Bureau regulate the rules for settling contracts of compulsory liability insurance of motor vehicles.

Based on Article 9 (2) of the Act, compulsory motor liability insurance covers damage caused intentionally or as a result of gross negligence of the insured (keeper of the vehicle) or the persons for whom he is responsible. The amount of compensation is limited to EUR 5m for bodily injury and EUR 1m for property damage. According to Article 43 of the Act, the insurance company has the right of recourse against the driver if he caused the damage intentionally or illegally took possession of the vehicle.

There is no fund or special entity in Poland responsible for the compensation of victims of terrorism. The Polish Insurance Guarantee Fund is solely focused on uninsured vehicles and accidents where the perpetrator was not identified.

On 21 September 2005 the Act on State Compensation for Victims of Certain Intentional Offences entered into force with a defined catalogue of reimbursable costs: these are limited to lost earnings and medical expenses up to PLN 12 000 (approximately EUR 2 850).


3 The country responses

3.6 Spain

Based on the Spanish Motor Third Party Liability Insurance Law (Real Decreto Legislativo 8/2004, de 29 octubre, Ley sobre Responsabilidad Civil y Seguro en la Circulación de Vehículos de Motor de 2004) there is no cover for damage caused by a terrorist act under MTPL policies. Article 6 of the Law on Motor Liability Insurance specifically states that the use of vehicles as instruments to perpetrate criminal acts against people and goods are not considered as traffic incidents and therefore out of scope of this law. The Insurance Contract Law, Article 19 (Ley de Contrato de Seguro), does not provide for coverage of intentional acts (dolo) in compulsory insurance.

Hence claims presented under (compulsory) MTPL policies are excluded from coverage. A legal debate among law scholars has started asking whether this would apply to additional voluntary MTPL insurance. Since there is no Supreme Court decision covering the same circumstances as those in Barcelona in August 2017, this remains to be seen.

The Consorcio de CompensaciÓn de Seguros (CCS) indemnifies victims for losses due to extraordinary events occurring in Spain, including acts of terrorism. Indemnity payments are limited to individuals who have bought accident and life insurance and have usual residence in Spain. In the particular circumstances of Barcelona, this resulted in payments by the CCS to insured Spanish people and foreigners with usual residence in Spain, though it did not benefit the many victims who were not policyholders.

Under Law No. 29/2011 on the Recognition and Integral Protection of the Victims of Acts of Terrorism (Ley 29/2011, de 22 de septiembre de Reconocimiento y ProtecciÓn Integral a las Victimas del Terrorismo), Spain has enacted a unified scheme setting out the assistance, support and protection to which victims of terrorism are entitled. The Law expressly recognizes all victims of terrorism as being victims of human rights violations, irrespective of questions of state responsibility. According to this regulation, the state is bound to compensate the victims of terrorist offenses for personal injury damages. Compensation is limited to specific amounts set for death or type of injury. Victims from other nationalities are also entitled to compensation. The amounts received under Law No. 29/2011 would accumulate with those received from other schemes. For the indemnity payment made pursuant to the Act, the state has subrogation rights against the offender if he has been convicted in criminal proceedings.

3.7 Sweden

The Traffic Damage Act (Trafikskadelag: SFS 1975: 1410) aims to disconnect the compulsory MTPL insurance from tort law and make it work like social insurance for the benefit of all victims. Consequently, based on Article 11 of the Act the MTPL insurer shall provide compensation for any personal injury or property damage resulting from the use of a motorized vehicle registered in Sweden. The protection is broad and unlike in many other European countries, the owner of the vehicle and the driver are entitled to compensation for bodily injury as well. Nevertheless, there is the limitation that pursuant to Article 12 of the Act compensation to the insured (vehicle keeper) or driver for their own bodily injury damage can be reduced if the damage was caused by their own intentional act.

The MTPL insurer is bound to indemnify even if the vehicle was stolen but has a right to take recourse against the driver. The maximum compensation for one event is SEK 300m (approximately EUR 30m).

Additionally, it is possible for victims of criminal offenses to get compensation from the government. Claims for such compensation are assessed by the Crime Victim Compensation and Support Authority.


3.8 Switzerland

Fundamentally, the MTPL insurance also encompasses losses caused through the use of a motor vehicle for terrorist purposes (Art. 58 para. 1 RTA, Road Traffic Act / Strassenverkehrsgesetz). A possibility of an exemption from liability is foreseen in case the accident is caused by gross negligence or intent of a third party and there is no negligence on the keeper’s part (Art. 59 para. 1 RTA). However, as the registered keeper of the motor vehicle is considered as responsible for the driver, even if the vehicle is used with a terrorist intent, the driver should not be considered as a “third party” and this exemption should not be applicable.

In summary, despite some dissenting views, it would appear that the MTPL insurer is at risk. Alternatively, victims would be compensated by the Insurance Guarantee Fund in case of lack of insurance coverage. Discussions have been triggered at the level of the Swiss Insurance Association to clarify the situation.

3.9 United Kingdom

UK MTPL policies typically exclude cover for losses caused by or arising out of the deliberate actions of the driver, unless the insurer is required to meet any claims by virtue of Section 145 (3)(a) of the 1988 Road Traffic Act. The question is whether although the insurer may exclude cover in such circumstances, the 1988 Road Traffic Act still requires the insurer to meet those claims. The answer was provided by the Court of Appeal in the case of EUI v Bristol Alliance Partnership (2012) where it was decided that where the use of the vehicle is not covered under the policy, as in the case of a terrorist attack, the insurer has no obligation under the 1988 Road Traffic Act to meet any claims that result.

However, the claims would then fall to be met by virtue of Article 75 of the Articles of Association of the Motor Insurers Bureau (MIB). The wording of that Article imposes an obligation on insurers to deal with any claims arising out of the use of the vehicle, even if such use is excluded under the motor policy wording. This means the insurer covering the vehicle would pay the claims without a right of recourse against the MIB. As the duty to compensate is based on a private agreement reached between UK insurers and the MIB, questions of cover and recourse arise in an international context (car licensed in a foreign country is used for an attack in the UK). This has remained unresolved to date.


4 Conclusion

The above description of the situation in the selected European countries in combination with the tabular representation of a few scenarios demonstrates that depending on the circumstances, any MTPL insurer can be exposed to claims resulting from the use of a motor vehicle for terrorist purposes. This even in presence of clear policy exclusions or where the legislation in the country of registration of the insured vehicle excludes coverage for intentional acts. The reasons for this are to be seen in the interplay of the Internal Regulations of the Council of Bureaux (former “Green Card Agreement”), the EU Convention on the law applicable to traffic accidents and the EU Directive relating to MTPL insurance, which can lead to foreign law superseding policy language or domestic regulation.

The following extreme, but unfortunately not unthinkable scenario can help to illustrate what amounts by order of magnitude we may have to consider: The hijacker of a bus insured by a French MTPL policy drives it into a crowded shopping alley in Brussels, leaving 100 people dead, 100 severely and 100 otherwise injured. If in a simplified calculation we only take an average loss of EUR 0.75 m per fatality, EUR 4m per severely injured person, and assuming EUR 25m for other injured persons and property damage, we come to a frightening EUR 500m loss for the insurer. Given the enormous potential of such claims, bearing such exposure in mind appears advisable to any MTPL insurer.


Overview

Country N°Terror Scenario involving a Motor Vehicle (MV)

MTPL Insurance Exposure Considerations

Belgium 1 MV registered in B, B MTPL insurer, attack in B through driving into crowd.

Yes Compulsory MTPL insurance also covers terror acts. A policy exclusion for intentional acts ought to be invalidated as a matter of law. TRIP reimburses MTPL insurer.

2 Stolen MV registered in B, B MTPL insurer, attack in B through driving into crowd.


3 Rented MV registered in B, B MTPL insurer, attack in B through driving into crowd.


4 MV registered in B, B MTPL insurer, attack abroad through driving into crowd.

Possible EU regulation/Green Card System applies and duty to compensate depends on law of country of attack.

5 MV registered abroad, foreign MTPL insurer, attack in B through driving into crowd.

Yes Belgium law applies and foreign MTPL insurer should indemnify (EU regulation/Green Card System).

France 1 MV registered in F, F MTPL insurer, attack in F through driving into crowd.

No FGTI compensates victims. Subrogation against F MTPL insurer is not possible as exclusion for intentional acts of any insured will apply.

2 Stolen MV registered in F, F MTPL insurer, attack in F through driving into crowd.


3 Rented MV registered in F, F MTPL insurer, attack in F through driving into crowd.


4 MV registered in F, F MTPL insurer, attack abroad through driving into crowd.

No Possible

FGTI compensates victims. Subrogation against F MTPL insurer is not possible as exclusion for intentional acts of any insured will apply in France. EU regulation/Green Card System applies and duty to compensate depends on law of country of attack.

5 MV registered abroad, foreign MTPL insurer, attack in F through driving into crowd.

Yes

No

In case no policy exclusion applies, FGTI compensates victims, but can subrogate against foreign MTPL insurer. A policy exclusion of the foreign MTPL insurer is valid according to the legislation in F as country of the attack. FGTI will compensate victims without a right to subrogate.




Germany 1 MV registered in G, G MTPL insurer, attack in G through driving into crowd.

No

Yes

Attack through keeper of MV as driver: Liability of keeper given, but no claim against MTPL insurer possible, as intentional and fraudulent acts are excluded (§ 103 Motor Insurance Act). Claim of injured third parties against Association for Traffic Victims is possible. Attack by authorised driver who is not keeper of MV: Claim against MTPL insurer is possible based upon § 115 Insurance Contract Act due to strict liability of keeper (§§ 7(1) and 12 Road Traffic Act).

2 Stolen MV registered in G, G MTPL insurer, attack in G through driving into crowd.

Yes

No

If driver could steel MV because of negligence of keeper: Claim against MTPL insurer possible based upon § 115 Insurance Contract Act. If driver could steel MV absent any negligence of keeper: Liability of MTPL insurer is excluded, as driver is liable instead of the keeper based upon § 7 (3) Road Traffic Act. Claim of injured third parties against Association for Traffic Victim is possible.

3 Rented MV registered in G, G MTPL insurer, attack in G through driving into crowd.

Yes Claim against MTPL insurer possible based upon § 115 Insurance Contract Act (as it is about an attack by an authorised driver who is not keeper of MV) and due to strict liabilty of the keeper (§§ 7(1) and 12 Road Traffic Act) .

4 MV registered in G, G MTPL insurer, attack abroad through driving into crowd.

Yes EU regulation/Green Card System applies and duty to compensate depends on law of country of attack.

5 MV registered abroad, foreign MTPL insurer, attack in G through driving into crowd.

German law applies to foreign actors and foreign MTPL insurer (see scenarios 1–3 above).

Italy 1 MV registered in I, I MTPL insurer, attack in I through driving into crowd.

Yes According to Civil Code (CC) intentional acts are not covered by MTPL policies. However majority of courts do not accept the coverage exclusion of the CC and confirm coverage in awards with a right of recourse against the liable person.

2 Stolen MV registered in I, I MTPL insurer, attack in I through driving into crowd.

Yes Majority of courts do not accept the coverage exclusion of the CC. MTPL cover can lapse after theft. In that case compensation is paid out by the Insurance Guarantee Fund.

3 Rented MV registered in I, I MTPL insurer, attack in I through driving into crowd.

Yes Majority of courts do not accept the coverage exclusion of the CC. MTPL cover can lapse after theft. In that case compensation is paid out by the Insurance Guarantee Fund.

4 MV registered in I,I MTPL insurer, attack abroad through driving into crowd.


5 MV registered abroad, foreign MTPL insurer, attack in I through driving into crowd.

Possible Italian law applies and foreign MTPL insurer should indemnify (EU regulation/Green Card System).

Overview




Poland 1 MV registered in P, P MTPL insurer, attack in P through driving into crowd.

Yes Compulsory cover, no exclusion for intentional acts applicable. Recourse against the driver possible.

2 Stolen MV registered in P, P MTPL insurer, attack in P through driving into crowd.


3 Rented MV registered in P, P MTPL insurer, attack in P through driving into crowd.


4 MV registered in P, P MTPL insurer, attack abroad through driving into crowd.


5 MV registered abroad, foreign MTPL insurer, attack in P through driving into crowd.

Yes Polish law applies and foreign MTPL insurer should indemnify (EU regulation /Green Card System).

Spain 1 MV registered in S, S MTPL insurer, attack in S through driving into crowd.

No Based on Law of Motorliability Insurance the use of a vehicle for criminal acts is not a covered use. Special scheme under Law 29/2011 indemnifies victims (all nationalities).

2 Stolen MV registered in S, S MTPL insurer, attack in S through driving into crowd.

No Special scheme under Law 29/2011 indemnifies victims (all nationalities).

3 Rented MV registered in S, S MTPL insurer, attack in S through driving into crowd.

No Special scheme under Law 29/2011 indemnifies victims (all nationalities).

4 MV registered in S, S MTPL insurer, attack abroad through driving into crowd.


5 MV registered abroad, foreign MTPL insurer, attack in S through driving into crowd.

Possible Special scheme under Law 29/2011 indemnifies victims (all nationalities). Recourse against foreign driver might be exercised under special conditions.

Sweden 1 MV registered in S, S MTPL insurer, attack in S through driving into crowd.

Yes MTPL insurance includes coverage for all victims with a right of recourse against the driver.

2 Stolen MV registered in S, S MTPL insurer, attack in S through driving into crowd.


3 Rented MV registered in S, S MTPL insurer, attack in S through driving into crowd.


4 MV registered in S, S MTPL insurer, attack abroad through driving into crowd.

Yes EU regulation/Green Card System applies and duty to compensate depends on law of country of attack.

5 MV registered abroad, foreign MTPL insurer, attack in S through driving into crowd.

Yes Swedish law applies and foreign MTPL insurer should indemnify (EU regulation /Green Card System).


Overview



Switzerland 1 MV registered in CH, CH MTPL insurer, attack in CH through driving into crowd.

Yes Compulsory cover likely and no exclusion for intentional acts applicable. Recourse against the driver possible.

2 Stolen MV registered in CH, CH MTPL insurer, attack in CH through driving into crowd.


3 Rented MV registered in CH, CH MTPL insurer, attack in CH through driving into crowd.


4 MV registered in CH, CH MTPL insurer, attack abroad through driving into crowd.

Possible EU regulation/Green Card System applies. Duty to compensate depends on law of country of attack.

5 MV registered abroad, foreign MTPL insurer, attack in CH through driving into crowd.


UK 1 MV registered in UK, UK MTPL insurer, attack in UK through driving into crowd.

Yes Victims to be indemnified based upon agreement of the Motor Insurers Bureau (MIB) with all UK MTPL insurers.

2 Stolen MV registered in UK, UK MTPL insurer, attack in UK through driving into crowd.


3 Rented MV registered in UK, UK MTPL insurer, attack in UK through driving into crowd.


4 MV registered in UK, UK MTPL insurer, attack abroad through driving into crowd.

Possible EU regulation/Green Card System applies. Duty to compensate depends on law of country of attack.

5 MV registered abroad, foreign MTPL insurer, attack in UK through driving into crowd.

Possible Duty to indemnify is unclear as agreement of MIB is only applicable to UK MTPL insurers and UK Road Traffic Act allows for certain policy exclusions (e.g. “use of vehicle other than that permitted under the policy”) to apply.

© 2018 Swiss Re. All rights reserved.

Authors: Yolanda Gügler, Andreas Hohl and Christian Lang with contributions from regional claims experts within EMEA Business Management

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