3.3.2. Specific CDD Measures for Insurers
In addition to performing general CDD on their customers, insurers are also expected to collect and verify the identities of any natural persons appointed to act on the customer’s behalf and are required, under Article 11 of the AML-CFT Decision, to collect and verify the identities of the beneficiaries or other payees of an insurance policy and their beneficial owners (where applicable), as set forth below.
3.3.2.1. Identification and Verification of Natural Persons Appointed to Act on a Customer’s Behalf
As per Article 8.2 of the AML-CFT Decision, where a customer appoints one or more natural or legal persons (such as an insurance broker) to act on his, her, or its behalf in establishing a business relationship with an insurer, the insurer must identify and verify the identity of each such natural person in accordance with the same procedures used to identify and verify the identity of a natural person customer. The insurer should also verify the due authority of each natural person appointed to act on behalf of the customer by obtaining, at a minimum:
• The appropriate documentary evidence authorizing the appointment of such natural or legal person by the customer to act on his, her, or its behalf; and
• The signature of such a natural or legal person appointed.
As with customers, natural persons appointed to act on a customer’s behalf should generally be identified and verified prior to establishing a business relationship. However, in exceptional circumstances, where there is no ML/FT suspicion, and ML/FT risks are assessed to be low, and where the deferral of verification is essential in order not to interrupt the normal course of business operations, an operator may complete the verification of the appointed person’s identity after establishing a business relationship, as set forth in section 3.3.3 below.
3.3.2.2. Identification and Verification of Beneficiaries or Other Payees and Their Beneficial Owners
Under Article 11.1 of the AML-CFT Decision, insurers are required to conduct CDD measures, including ongoing monitoring, with respect to any beneficiary of life insurance and other investment insurance insurance products, including life insurance products relating to investments and family Takaful insurance, as soon as the beneficiary is identified or designated. In addition, as soon as a beneficiary or other payee is designated, an insurer must perform the following:
• For a beneficiary or payee who is identified as a specifically named natural person, legal person, or legal arrangement, obtain the full name, including any aliases, of such beneficiary or payee; or • For a beneficiary or payee who is designated by characteristics, class, or other means, obtain sufficient information concerning the beneficiary or payee to satisfy itself that it will be able to establish the identity of such beneficiary or payee at the time of payout. • At the time of payout, insurers must also verify the identities of all beneficiaries or payees and their beneficial owners in accordance with the same procedures used to identify and verify the identity of a natural person customer.