3.3.3. Simplified Due Diligence for Lower-Risk Scenarios

Effective from 31/10/2022

As per Article 4.3 of the AML-CFT Decision, an insurance operator may perform simplified due diligence (“SDD”) measures in relation to a customer, a beneficial owner of a customer, a natural person appointed to act on behalf of a customer, or a beneficiary or other payee if it is satisfied that the risks of ML/FT are low. The assessment of low risks should be supported by an adequate analysis of risks by the insurance operator, and the selection of simplified measures should be commensurate with the type and level of risk identified through such risk analysis. In all cases, the operator should document the details of its risk analysis and the nature of the SDD measures employed.

Examples of potentially lower-risk scenarios include, but are not limited to, those in which:

	•	The customer is a UAE government entity, including UAE state-owned enterprises;
	•	The customer is an entity listed on a stock exchange and subject to regulatory disclosure requirements relating to adequate transparency with respect to beneficial owners;
	•	The insurance product does not offer cash payouts except upon the occurrence of specified trigger events;
	•	The insurance product does not have an early surrender option and cannot be used as collateral; or
	•	The insurance product is a pension or other scheme where contributions are made via deduction from wages and scheme rules and do not permit the assignment of a member’s interest under the scheme.

Additional examples of lower-risk attributes for the insurance sector are provided in section 2.2 above.

Where an insurance operator is satisfied that the ML/FT risks are low, the operator may perform one or more of the following SDD measures, as warranted by the risk analysis:

	•	Verifying the identity of the customer and any beneficial owner(s) after establishing the business relationship, provided verification is nonetheless completed in a timely fashion (to be documented in the operator’s internal procedures) and appropriate controls are in place to manage the ML/FT risks associated with the customer and the relationship prior to verification;¹¹
	•	Reducing the frequency of updates to CDD information;
	•	Reducing the degree of ongoing monitoring and scrutiny of transactions, based on a reasonable monetary threshold; or
	•	Developing an understanding of the intended nature and purpose of the customer relationship on the basis of the relationship type and the customer’s historical transaction activity, rather than by collecting information regarding the intended nature and purpose of the relationship during onboarding or CDD updating.

An insurance operator should not perform SDD measures where:

	•	A customer or any beneficial owner of the customer is from or in a country or jurisdiction against which the FATF has called for countermeasures;
	•	A customer or any beneficial owner of the customer is from or in a country or jurisdiction known to have inadequate AML/CFT measures, as determined by the operator for itself or notified to operators generally by local regulatory or supervisory authorities; or
	•	The operator suspects that ML or FT is involved.

¹¹ Such measures may include holding funds in suspense or escrow until verification of identity has been completed or making completion of identity verification a precondition of closing any transaction with or on behalf of the customer.