AML Made Simple with Aviva CPD Webinar for Financial Brokers 2 March am

Transcription

1 AML Made Simple with Aviva CPD Webinar for Financial Brokers 2 March am Your presenters: Richard Caffrey Bernie Brennan Caroline Doory

2 Welcome Richard Caffrey

3 Why do we need to Carry out Customer Due Diligence (CDD)? The Criminal Justice Acts 2010 & 2013 require all Designated Persons to carry out Customer Due Diligence It is a key factor in preventing and detecting Money Laundering and Terrorist Financing We must carry out CDD at new business and key stages Why are the CDD requirements not the same across the board in the insurance industry?

4 Product Risks Risk Category Product Group What level of CDD is required? Source of Funds Source of Wealth Lower Pension and Protection Products Identify the customer only no documentary evidence required Required for All Not Required Higher Savings and Investment Products Identify the customer and get documentary evidence Required

5 Who do we need to CDD? Individual Customers Entity Structures The Entity The People who Own & Control it

6 CDD Requirements for People where verification is required Acceptable Documents to Verify Identity In Date Drivers License In Date National Identity Card In Date Passport Acceptable Documents to Verify Address Letters issued by Financial Institution NEW Utility Bill, including Mobile Phone Bills, Original & E- Statement NEW Statement of Account from a Financial Institution Original & E-Statement NEW Instrument of Court Appointment stamped by the court Current household / motor insurance / tax documents All must be no more than 6months Official Documents issued by the Department of Social Protection / Revenue

7 Appropriate Documents The Application form has been updated to include the acceptable list of documents

8 CDD Requirements for Entities Identify 1. What? The name of the entity The address The legal form 2. Who Owns the entity? 3. Who Controls the entity? To Verify this Incorporated Entity: Certificate of Incorporation A company print out from the CRO, Solo Check, Vision Net etc Charities: Evidence of Revenue Approval plus the charity constitution / formation document Other Types: Trusts: Trust Deed Clubs / Associations: Constitution / Formation Document Obtain a list of all 25% Beneficial owners and get CDD for those people. This is to be on headed paper from the entity and signed by a Director/ Principal / Trustee depending on the entity type. Obtain a list of the Directors / Principals / Trustees of the entity and obtain CDD for 2 of those people. This is to be on headed paper from the entity and signed by a Director/ Principal / Managing Partner / Trustee depending on the entity type. Obtain a list of authorised signatories

9 List of Authorised Signatories Key Features: Headed Paper Who is authorised & specimen signature for each Signed by Directors / Principals The following requirements could also be included within the same letter: List of Directors List of Beneficial Owners & their % shareholding.

10 New Business To certify or not to certify, that is the question! AML RISK How to ensure Broker meets customer face to face & sees original documents? CERTIFY ERROR & DELAY

11 Certification Requirements New Business New Business Stage: 1+1 Certified Broker to provide: 1 copy of photo ID 1 copy of address verification Entity verification documents in the case of an entity proposal The completed application form which has been signed by you / your office must accompany the documents If all the above are received together there is no need for documents to be separately verified.

12 Existing Business CDD Requirements We will not ask for new CDD documents at claim stage if there is: CDD is on file from the new business stage, and no change to the Customer s Address, and no change to the Customer s Name If the customer s details have changed or if there are no CDD documents on file then we will require new CDD documents: 2 Proofs of Address and 1 Proof of ID (2+1) uncertified, or 1 Proof of Address +1 Proof of ID certified in the traditional way

13 Your Responsibilities as a Designated Person Implement Policies and Procedures to prevent and Detect Money Laundering & Terrorist Financing 1. Obtaining CDD 2. Obtaining information about the customer on the intended nature of the business relationship with the customer 3. Monitoring of business relationship with the customer 4. Staff Training 5. Identification and Reporting of suspicious activity 6. Retention of records

14 The Dangers of Getting it Wrong!

15 Making it easier to do business with us savings and investments New online support dedicated section on Avivabroker.ie to help you pre-sale.

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19 Making it easier to do business with us savings and investments Developed market leading application forms for Limited companies.

20 New Business Process 3 easy steps Step 1 Step 2 Send us the application ( or post) Use checklists at front to ensure you have given us everything we need and that application is fully completed. Your case handler will contact you to confirm receipt and let you know next steps. If all requirements received we can make the policy live same day We now accept payments by EFT Step 3 Policy documentation issued within 2 days of policy going live

21 Common problems when investing customers money Product type Commission structure. In date customer address verification (6 months) Valid documents (checklist) Clear ID PPS number missing Source of funds

22 Making it easier to do business with us savings and investments customer online access We now have online access for our new investment bond customers. Please ensure you give us their address. Presentation title here page 22

23 Claim forms on-line Presentation title here page 23

24 Simplified process for your client to get their money back high risk products need full AML and CDD on file. Checks: Full AML on file Not Assigned Not In Trust No change of address in the last 2 years Payment by EFT Is your customers claim amount less than 100k? - Yes Is the policy a single premium unit linked policy - Yes Do we hold customer CDD on file? - Yes We can pay your customers claim over the phone and by EFT

25 Simplified process for your client to get their money back lower risk products Checks: Not Assigned Not In Trust No change of address in the last 2 years Payment by EFT to a known account No change in DD details in the last 13 months At least 2 premiums have been paid from the account within the last 13 months Is your customers claim amount less than 100k? - Yes Is the policy traditional with profit or unit linked Protection? - Yes We can pay your customers claim over the phone and by EFT

26 Making it easier to do business with us In summary - Review of our AML and CDD requirements and the recent changes we have made to make It easier to do business - Online support and dedicated section and quotation engine on Avivabroker.ie to help you pre-sale - First to market new standalone corporate application forms for regular premium savings and single premium investments - New business process recent lessons learned - Customer online what your customer will see - Claims process forms online, Tele-claims

27 Ongoing Support Non standard and company queries for new business and claims Who Your Broker Consultant Broker Service Centre How (if ringing from mobile) Non Standard Queries BSC Paul Nolan, Paul Doggett, Katie Moran, Jenny Molloy and Tara Newman

28 Questions

29 Thank you