3.7. Employee, Officer, Agent, and Broker Risk Management

Effective from 31/10/2022

Insurance operators should have in place screening procedures to ensure high standards when hiring employees, appointing officers, or engaging agents or brokers (including but not limited to outsourced entities, as described in section 3.6.2 above). Employee, officer, and agent or broker screening procedures should include:

	•	Background checks of employment history; and
	•	Screening against sanctions lists, ML/FT information sources, and internal watchlists.

In addition, insurance operators should conduct credit history checks on a risk basis. The operator should be aware of potential conflicts of interest for staff with AML/CFT responsibilities and should act to reduce or manage such conflicts of interest, for example by reallocating responsibilities or by instituting quality controls and “four-eye” reviews of the conflicted employee’s work.

Operators should also monitor on an ongoing basis for possible indicators of suspicious or illicit behavior by employees, such as:

	•	An employee whose lifestyle cannot be supported by his/her salary, which may indicate receipt of tips or bribes.
	•	An employee who is reluctant to take a vacation, which may indicate they have agreed or are being forced to provide services to customers in violation of the law or company policy.
	•	An employee who is associated with an unusually large number of transactions or a transaction in an unusually large amount, which may indicate they have agreed or are being forced to provide services to customers in violation of the law or company policy.