3.6.1. Third-Party Reliance

Effective from 31/10/2022

Insurers are permitted to rely on third-party LFIs to perform the elements of general CDD described in sections 3.3.1.1 through 3.3.1.3, provided the insurer relying on a third party:

	•	Immediately obtains the necessary CDD information concerning the elements described in sections 3.3.1.1 through 3.3.1.3;
	•	Takes adequate steps to satisfy itself that copies of identification data and other relevant documentation relating to the CDD requirements will be made available from the third party upon request without delay;
	•	Satisfies itself that the third party is regulated, supervised, or monitored for, and has measures in place for compliance with, CDD and recordkeeping requirements in line with FATF standards and local law and regulation; and
	•	Takes appropriate steps to identify, assess, and understand the ML/FT risks specific to the countries or jurisdictions in which the third party operates.

With respect to the second of these conditions, a best practice is for insurers to obtain a copy of the relevant CDD records or have direct access to the database where such information is held, in order to facilitate ongoing monitoring of the business relationship and, if applicable, the filing of STRs and for a complete assessment record in case of a change of intermediary servicing the policy.

Insurers are not permitted to rely on third parties to conduct ongoing monitoring of business relationships (described in section 3.3.1.4), although they may outsource such functions following the guidelines described immediately below.