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3.3.2.1. Identification and Verification of Natural Persons Appointed to Act on a Customer’s Behalf

Effective from 31/10/2022

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.