For life insurance and other investment-related insurance products, insurance operators must perform customer due diligence (“CDD”) on their customers, defined as natural persons, legal persons, or legal arrangements with whom an insurer, agent, or broker establishes or intends to establish a business relationship to carry out insurance operations, as defined in Articles 4 and 5 of the Insurance Law.

Unless otherwise specified below, the customer of an insurance operator is the existing or prospective policyholder, defined as the natural person, legal person, or legal arrangement who owns and maintains the contractual rights of the insurance policy. Where the insurer is acting as a reinsurer, the customer will be the insurer (or reinsurer) in whose name the reinsurance policy is issued. Additionally, in the case of group life insurance or other policies, when the insured persons have active powers on the contract (e.g., to inject sums into the contract, establish the beneficiary, or exercise early surrender of the amounts), those persons should be considered equal to customers, and life insurers and relevant intermediaries should therefore conduct CDD on these persons, as well as on their related third parties. In cases where the insured persons have no active powers, their names should be screened against sanctions lists, but they are not considered customers for AML/CFT purposes, and insurers and intermediaries are not required to conduct full CDD checks on them.

Finally, although in most cases the policyholder will also be the party who pays the necessary premium to keep the policy in force, there may be exceptional cases in which the policy payer is an unrelated third party (referred to as a third-party payer). In such cases, the insurer—or its agent, under a third-party reliance or outsourcing arrangement, if applicable—should perform the following general CDD measures on both the policyholder and the third-party payer.