All risks cover? Not for the risk of non-existent goods

Ben Gardner, of Quadrant Chambers, reviews Engelhart CTP (US) LLC v Lloyd's Syndicate 1221 and coverage for loss resulting from fraudulent acceptance of goods

Open cover insurance on goods on “all risks” terms has been described as “broad” and providing the “flexibility and continuity of cover which are essential to enable a large trading organization to carry on business in the modern world” (Glencore International AG v Alpina Insurance Co Ltd [2004] 1 Lloyd’s Rep 111, para 10). It is rightly seen as providing insurance for a very wide range of risks that a trading company might face in modern commerce.