In an outsourcing or agency scenario, the outsourced entity applies CDD or other AML/CFT measures on behalf of the delegating insurer, in accordance with the insurer’s internal policies and procedures, and is subject to the insurer’s control of the effective implementation of those policies and procedure by the outsourced entity. When outsourcing a part of their AML/CFT function, including the distribution of products, an insurer should therefore include any outsourced entity in its own AML/CFT program and internal control processes, and should monitor such an entity for compliance with its internal AML/CFT policies and procedures. Outsourced entities should also be subject to the employee and agent screening and monitoring checks described immediately below.