ORIGIN OF WEALTH GUIDELINES For financial advisers only

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Benedict Norman
6 years ago
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1 OIGI OF WEALTH GUIDELIES For financial advisers only background The Isle of Man subscribes to global efforts to combat financial crime and terrorist financing, and to this end has introduced regulatory requirements which are binding on all Isle of Man life offices and Isle of Man branches of overseas life offices, including Old Mutual Isle of Man. Based on assessed risk, which is determined by a number of factors, including the size of the investment, the client s country of residence, the source of funds, ownership by legal entities, etc, a life office may have to obtain additional information and documentation, which may include documentary evidence of source of funds and the origin of the client s wealth. This evidence safeguards the interests of the Isle of Man, the life offices and it protects the client too. All references to we, us and our in this document mean Old Mutual Isle of Man. This document does not give guidance on where Old Mutual Isle of Man can accept business from. It should only be used as guidance for financial crime risk purposes. For example, Old Mutual Isle of Man may be able to accept premiums from a country listed in this document, but we would not accept business from a resident of that country. If you have any questions regarding acceptance of business from a particular country then you should contact your Old Mutual International Offshore Specialist. As part of the global efforts to prevent financial crime, Isle of Man authorised life companies may adopt a risk-based approach when obtaining physical evidence of the origin of a client s wealth. This does not question the quality of the investment and the risk ratings shown in this document have no relevance to the volatility and returns of the investment. It is a safeguard that will benefit the industry as a whole and ultimately protect the client as an investor. how does your client provide the information we need? Your client needs to provide origin of wealth information which describes how the funds being invested have been accumulated. When completing the details in the relevant section of the application form, please make sure generic descriptions are not used and include appropriate references where applicable. For example, if the origin of wealth is the redemption of another life assurance policy, please include details such as the name of the life assurance company, policy number and reason for redemption. isk rating and premium levels If the premium is above the levels in the table for the risk ratings shown below, then you also need to make sure that the relevant documentary evidence accompanies the application form as detailed on page 4. If your client is resident in, and funding from South Africa, Isle of Man, Jersey, Guernsey or United Kingdom, the limit for investment increases to GBP,000, or currency equivalent* before documentary evidence is required. *Exchange rates for converting currency into GBP: US$.5 EUO. CHF.5 AU$.5 ZA 0.00 Total risk rating Premium* >,000,000-4 > 400, > 00,000 These limits are cumulative. All Isle of Man insurers have a regulatory obligation when considering any application for a new policy or additional investment to take into account all previous investments made by a policyholder, regardless of when the investment was made.

2 To comply with regulations Old Mutual Isle of Man may deem it necessary to request further documentation if it is felt appropriate regardless of risk rating or premium level. If a client is a politically exposed person or linked to one, the risk of the business will automatically be classed as high. Origin of wealth evidence must be provided with the application and funding must come from the client s personal bank account. how do I determine the total risk rating? In order to determine what risk rating applies to your client s investment you need to take into account the following factors: (a) your client s country of residence* (b) the country the premium is sent from If a country has an rating then please refer this business to your Old Mutual International Offshore Specialist. If a country has an rating then Old Mutual Isle of Man will not accept the business. Client s country of residence that the premium Total risk rating is paid from South Africa () Mauritius () () Based on this example, if we assume your client is investing a premium in Sterling, then you would need to provide further documentary evidence if the premium is above GBP400,000. * For regulatory and legal reasons we may be unable to accept business from a resident of a country listed in the table on page, such as the USA. However, if a person is resident in South Africa but paying a premium from a bank account in the USA, that would be acceptable. risk ratings We have assigned a rating to a number of countries based on the evaluation carried out by international bodies, including the Financial Action Task Force (FATF). We have taken these evaluations and produced ratings based on each country s financial crime risk. These are shown in the following tables. The country ratings could be subject to changes in the future. Australia Gibraltar Malta Austria Guernsey etherlands Barbados Hong Kong ew Zealand Belguim Hungary orway British Virgin Islands Iceland Panama Bulgaria Ireland Portugal Canada Isle of Man Singapore Chile Israel Slovenia Colombia Italy South Africa Cyprus Jersey Spain Denmark Japan Sweden Estonia Lithuania Switzerland Finland Luxembourg United Kingdom France Macau Uruguay Germany Malaysia USA

3 Albania Greece Poland Bahamas Guatemala Qatar Bahrain India omania Brazil Jamaica Saudi Arabia Brunei Darussalam Latvia Slovakia Cayman Islands Mauritius South Korea China Mexico Taiwan Czech epublic Montenegro Tunisia Egypt Oman Turkey El Salvador Peru United Arab Emirates Algeria Grenada evis and St Kitts Andorra Guyana Papua ew Guinea Anguilla Jordan Puerto ico Antigua Kosovo Senegal Argentina Kuwait Serbia Barbuda Laos Seychelles Belize Lebanon Sri Lanka Bermuda Lesotho St Lucia Bosnia & Herzegovina Liechtenstein Swaziland Botswana The Former Yugoslav epublic of Macedonia Thailand Cape Verdi Madagascar Togo Costa ica Malawi Trinidad & Tobago Croatia Maldives Vanuatu Cuba Monaco Venezuela Dominica Morocco Zambia Dominican epublic Fiji Mozambique amibia Azerbaijan Kenya Philippines Bolivia Mongolia Tanzania Ecuador icaragua Uganda Honduras igeria Vietnam Indonesia Pakistan Zimbabwe Ivory Coast Paraguay Afghanistan Iran ussia Angola Iraq Sierra Leone Armenia Kazakhstan Somalia Bangladesh Kyrgyzstan Sudan Belarus Liberia Suriname Cambodia Libya Syria Cameroon Mali Tajikistan Democratic epublic of Congo Moldova Turkmenistan Cook Islands Myanmar Turks & Caicos Ethiopia auru Ukraine Gambia epal Uzbekistan Georgia iue Yemen Ghana Haiti orth Korea orthern Cyprus KEY = low risk = medium risk = high risk = always refer this business to your Old Mutual International Offshore Specialist = Old Mutual Isle of Man cannot accept this business

4 further documentary evidence requirements If the premium is above the levels shown on page then the table below describes guidance on what documentary evidence is required to support each application. If you are still unsure about what is required or your client is having difficulty supplying the relevant documents then you should contact your Old Mutual International Offshore Specialist or local branch. Alternatively you can contact Old Mutual Isle of Man ew Business Team directly on +44 (0) If you are sending copies of documents, these should be certified as a true copy of the originals; see overleaf. Description of source of wealth Company sale Compensation payment Gift Income from employment/income from business Other unearned income Inheritance Investment Loan Maturing investment/policy claim/ eplacement policy Property sale Savings Share sale Win Other Documentary evidence required signed letter from regulated accountant copy of contract of sale and sight of investment monies on bank statement copies of media coverage (if applicable) as supporting evidence letter/court order from compensating body All of the following: identification on the grantor (even if it is not coming from their account) letter from grantor explaining the gift and source of their wealth documentary evidence as to the grantor s source of wealth as detailed in this table One of the following or equivalent: original copy of recent payslip (or bonus payment) recent accounts if self-employed bank statement clearly showing receipt of most recent three months regular salary payments from named employer employer letter confirming annual salary signed by the Human esources Manager or an equivalent Senior Manager of the firm All of the following: appropriate supporting documentation signed letter detailing income from a regulated accountant grant of probate (with a copy of the Will) which must include the value of the estate the Will investment certificates, contract notes or statements confirmation from the relevant investment company bank statements showing receipt of payment by investment company name signed letter detailing payments from a regulated accountant or solicitor confirmation letter from loan provider recent loan statement letter from previous product provider regarding notification of proceeds of claim closing statement from previous product provider One of the following or equivalent: or regulated accountant; or signed letter from estate agent (if applicable); or copy of sale contract Copy of a bank statement covering a month period which shows total savings from accumulated wealth. If the statement does not evidence the accumulation, please also supply one of the listed documents above. E.g. If savings is from income, please supply one of the required documents from the income section. legal sale document copy of contract notes letter from relevant organisation (lottery headquarters, betting shop, casino) bank statement showing funds deposited by company name copies of media coverage (if applicable) as supporting evidence efer to Old Mutual Isle of Man The evidence supplied must support the details stated in the relevant section of the application and cover the total investment. 4

5 certifying documents Unless the documents provided are originals, they will need to be certified by a suitable certifier. For some cases we may need official documents or extracts to be certified by an independent third party, see below. A suitable certifier can be a Commissioner of Oaths, solicitor, lawyer or advocate. When certifying a document, the suitable certifier must include the following wording: Certified a true copy of the original document, which I have seen and / or a true likeness of the person represented thereon. The suitable certifier must also sign and print their name, state their company name, their position within the company and the date. UK lasting powers of attorney and UK enduring powers of attorney can be certified by the settlor, a solicitor or a notary only. Old Mutual Isle of Man, Branch of Old Mutual Life Assurance Company (South Africa) Limited, is registered in the Isle of Man under number F and whose principal place of business is King Edward Bay House, King Edward oad, Onchan, Isle of Man, IM99 U, British Isles. Phone: +44 (0) Fax: +44 (0) Licensed by the Isle of Man Financial Services Authority. Old Mutual Life Assurance Company (South Africa) Limited is incorporated in South Africa (reg. number: 999/0464/06). egistered office: Mutualpark, Jan Smuts Drive, Pinelands, Cape Town, South Africa. Old Mutual Life Assurance Company (South Africa) Limited is a registered long-term insurer and a licensed financial services provider. SK799/IT-870/January 0

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Argentina Bahamas Barbados Bermuda Bolivia Brazil British Virgin Islands Canada Cayman Islands Chile Americas Argentina (Banking and finance; Capital markets: Debt; Capital markets: Equity; M&A; Project Bahamas (Financial and corporate) Barbados (Financial and corporate) Bermuda (Financial and corporate)