SUPPLEMENTARY INFORMATION Appendix FC- (iv) Examples of Suspicious Transactions

Similar documents
United Republic of Tanzania Financial Intelligence Unit Anti Money Laundering and Counter Terrorist Financing Guidelines to Insurers

Anti-Money Laundering Awareness Training Insurance Industry-Hong Kong

INSURANCE REGULATORY AUTHORITY

3.1 The legislation defines the offences relating to money laundering as:

ANTI-MONEY LAUNDERING TRAINING FOR AGENTS TRANSAMERICA LIFE & PROTECTION

Guideline on Combating Money Laundering and Terrorist Financing

GUIDELINES TO MAS NOTICE 314 ON PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM

Relevant Legislation

FIU G3: Anti-Money Laundering and Combating the Financing of Terrorism Guideline for Insurance Companies 2014

Anti-Money Laundering Policy

ANTI-MONEY LAUNDERING POLICY

GIfCS FATF TYPOLOGIES REPORT MONEY LAUNDERING RISKS ARISING FROM TRAFFICKING IN HUMAN BEINGS AND THE SMUGGLING OF MIGRANTS

Guidance Note on Prevention of Money Laundering and Terrorist Financing. The Office of the Commissioner of Insurance

Legal Digest. The Fight Against Money Laundering. Naina Parwani & Tan Loo Ying. An online repository of various articles published by our lawyers

INTERNAL CONTROL POLICIES AND PROCEDURES (As envisaged under the Prevention of Money Laundering Act, 2002)

NOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186

DIRECTIVE NO.DO1-2005/CDD

AC NOTE FICA. What FICA governs and requires

Ordinance of the Swiss Federal Banking Commission Concerning the Prevention of Money Laundering

FINANCIAL CRIME MODULE

- Due diligence process is a continuous process customer service representatives (C/S Rep.) need to be aware of:

Financial and Commercial Services UNIVERSITY OF BRADFORD ANTI-MONEY LAUNDERING POLICY

CAPITAL MARKET AUTHORITY. Anti-Money Laundering and Counter-Terrorist Financing Rules

Questions: Who does the agent work for? What was the agent doing at the time of the incident?

Anti Money Laundering and Combating Financing of Terrorism

Merseytravel Anti Money Laundering Policy and Procedures (DCD/49/12) Report of the Director of Corporate Development

Designation of 'Principal Officer' and 'Designated Director' as required under the Prevention of Money Laundering Act.

SFC consultation paper on proposed anti-money laundering and counterterrorist

FICA MANUAL. Definitions 4. The Financial Intelligence Centre Act 6. Objective in terms of the FIC Act 6. The Financial Intelligence Centre 7

Legitimate interests of Bluefin (to ensure that the client

SESSION 3. RED FLAGS & Counter Terrorist Financing

Credit institutions 1. II.2. Policy statement

ANTI-MONEY LAUNDERING POLICY

CITIZENS, INC. BANK SECRECY ACT/ ANTI-MONEY LAUNDERING POLICY AND PROGRAM

BGLC WELCOMES YOU TO THE Anti-Money Laundering Training Session now Proceeds of Crime Act (POCA) 2007:

Anti-Money Laundering Policy and Procedure

ANTI-MONEY LAUNDERING PROGRAM Applicable to:

FMA Guideline 2005/1. Monitoring of business relationships

PCM Brokers DMCC. Anti-Money Laundering Policy

Payroll Agents Sector Specific AML/CFT Guidance Notes December 2015

CAYMAN ISLANDS MONETARY AUTHORITY

Accountants and Tax Advisors

Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Employee & Agent Training

Anti-Money Laundering Policies and Procedures. Arif Habib Limited

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

Administrative Rules for the Reporting of Large Value and Suspicious Transactions by Financial Institutions (2007)

Update No (Issued 28 February 2018) Document Reference and Title Instructions Explanations

Anti-Money Laundering Policy

JERSEY FINANCIAL SERVICES COMMISSION 5 TH ANNIVERSARY SEMINAR FATF REVISED 40 RECOMMENDATIONS

OT MARKETS PTY LTD MARKETS AML MANUAL

Produced by Corbin Communications Ltd.

Direct Debit Authorization Form (Banking)

Policy on Prevention of Money Laundering Policy

Charity & Charity Trustees' Liability Proposal Form

ANTI-MONEY LAUNDERING POLICY

Guideline on Anti-Money Laundering and Counter- Terrorist Financing

July 2017 CONSULTATION DRAFT. Guidelines on. Anti-Money Laundering. and. Counter-Terrorist Financing for Professional Accountants

PART III BANKS AND OTHER DEPOSIT TAKING FINANCIAL INSTITUTIONS SECTOR SPECIFIC AML/CFT GUIDANCE

FM Marketing LTD AML MANUAL

CONTINENTAL REINSURANCE ( C Re ) ANTI-MONEY LAUDERING/COUNTERING THE FINANCING OF TERRORISM (AML/CFT) POLICY

Anti-Money Laundering Policy (AML)

Anti-Money Laundering

ANNEX III Sector-Specific Guidance Notes for Investment Business Providers, Investment Funds and Fund Administrators

Set of Indicators for Corruption Related Cases. From the FIUs Perspective

Government Personnel Mutual Life Insurance Company. Anti-Money Laundering (AML) Program; Including Suspicious Activity Reports

ANTI-MONEY LAUNDERING AND COUNTER TERRORISM FINANCING PROCEDURE MANUAL. Fcorp Services Ltd

ANTI MONEY LAUNDERING POLICY C D COMMODITIES BROKING LTD

1. INTRODUCTION APPLICABILITY DEFINITION Money Laundering Financing of Terrorism CUSTOMER ACCEPTANCE

PRACTICE CIRCULAR ON THE PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM 08-13

Guidelines for Compliance with Canada s Anti-Money Laundering and Terrorist Financing Regime

Money Laundering and Terrorist Financing: Definitions and Explanations

PART IV FIDUCIARY (COMPANY FORMATION AND TRUSTS) SECTOR SPECIFIC AML/CFT GUIDANCE NOTES

Anti- Money Laundering & Combating Financing of Terrorism. Training for Insurance Agents By Joseph Owuor

The Risk Factors Guidelines

GENERAL SCHEME OF A CRIMINAL JUSTICE (MONEY LAUNDERING AND TERRORIST FINANCING) (AMENDMENT) BILL

POLICY AND PROCEDURES FOR ANTI MONEY LAUNDERING ACT

Producer s Guide to Anti-Money Laundering

The Financial Advisor Guide to Money Laundering. Self Study Course # 25

SUSPICIOUS TRANSACTIONS AND ANTI-MONEY LAUNDERING GUIDELINES

FINANCIAL CRIME MODULE

Customer Identification Procedures for Brokers

$OOÃULJKWVÃUHVHUYHGÃ$SSOLFDWLRQVÃIRUÃSHUPLVVLRQÃWRÃUHSURGXFHÃDOOÃRUÃSDUWÃRIÃWKLVÃSXEOLFDWLRQ

Application Form. Dear Client,

ANTI-MONEY LAUNDERING COMPLIANCE GUIDE

Proper management of your account will safeguard both your finances and those of the wider community

Trans-Fast Remittance LLC. AML Compliance Training for Agents

Montpelier Reinsurance Ltd. and its subsidiary. Consolidated Financial Statements December 31, 2014 and 2013 (expressed in millions of U.S.

Developments in Anti-Money Laundering Regulation for Investment Advisers and Funding Portals. May 2016

Anti-money Laundering Bulletin

MONEY LAUNDERING AND TERRORIST FINANCING "RED FLAGS"

Targeting Illicit Financial Flows

Regulation on non-trading transactions and the KYC/AML policy

IDENTITY VERIFICATION FORM (for use where the customer is a corporation) 1. This form should be completed by the licensee serving the customer.

Guideline to trustees for the submission of reinsurance contracts to the Registrar of Medical Schemes in terms of Section 20 of the Medical Schemes

BERMUDA PROCEEDS OF CRIME (ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING) REGULATIONS 2008 BR 77 / 2008

Market-Hub Stock Broking Pvt. Ltd. Version: MHSBPL/05

Appendix A Anti-Money Laundering and Countering the Financing of Terrorism Code

ANTI MONEY LAUNDERING PROCEDURE

READING COMMUNITY LEARNING CENTRE

The Audit of Licensed Corporations and Associated Entities of Intermediaries

Transcription:

SUPPLEMENTARY INFORMATION Appendix FC- (iv)

History Change Date October 2005 Initial Launch Description of Changes : History October 2005 Page 1 of 1

Appendix FC (iv): Introduction This Appendix provides some examples of transactions where an insurance firm or insurance broker would be expected to make further enquiries to satisfy themselves as to the genuineness of the transaction and the source of the funds. In the event of failure to do so, and the transaction subsequently being discovered to involve funds that are the proceeds of crime, then the firm or broker (and the employees and agents concerned) could render themselves liable to prosecution, if they have not complied with the reporting requirements given in these regulations. October 2005 Page 1 of 6

New Business Examples of new business-related suspicious transactions include: (a) A personal lines customer that is unable or reluctant to provide satisfactory evidence of identity, or where the evidence presented is out of date, of poor quality or does not provide conclusive evidence; (b) A personal lines customer who provides evidence of identity on behalf of another proposer, where it would be considered appropriate for the proposer to attend in person, and where the proposer is unable or reluctant to attend in person (where it would be reasonably to do so and in the absence of extenuating circumstances); (c) A proposer with no discernible reason for purchasing insurance, e.g. a life policy with an unusually high limit where the proposer has no outstanding mortgage and no dependants, or where the insurance is bought at abnormally high cost or the product is otherwise unsuitable; (d) A proposer for a savings product, and/or an intermediary, where either or both are based in countries where production of drugs or drug trafficking may be prevalent; (e) A proposer who is not resident and where the purchase of an insurance policy in Bahrain appears abnormal or suspicious; (f) Any transaction in which the insured is unknown (e.g. business introduced under binding authorities); (g) A proposal from an intermediary not in keeping with the normal business introduced; (h) A proposal not in keeping with an insured s normal requirements, the markets in which the insured or intermediary is active and the business which the insured operates; (i) Any transaction in which the nature, size or frequency appears unusual, e.g. early termination or cancellation, especially where cash had been tendered and/or the refund cheque is to a third party; (j) A transaction not in keeping with normal practice in the market to which they relate, e.g. with reference to size or class of business; (k) Other transactions linked to the transaction in question which could be designed to disguise money and divert it into other forms or other destinations or beneficiaries; (l) Willingness to pay premium on high risks which have a likelihood of regular claims being made; and (m) An attempt was made to purchase life policies for a number of foreign nationals. The underwriter was requested to provide life coverage with an indemnity value the same as the premium. There were also indications that in the event that the policies were to be cancelled, and return premium was to be paid into a bank account in a different jurisdiction to the assured. October 2005 Page 2 of 6

Premiums Examples of premiums-related suspicious transactions include: (a) A number of policies taken out by the same insured for low premiums, each purchased for cash and then cancelled with return of premium to the third party; (b) Large or unusual payment of premiums or transaction settlement by cash; (c) Overpayment of premium with a request to refund the excess to a third party or different country; (d) Payment by way of third party cheque or money transfer where there is a variation between the account holder, the signatory and the prospective insured; (e) Another strategy involves the purchase of large, single-premium insurance policies and their subsequent rapid redemption. A money launderer does this to obtain payment from an insurance company. The person may face a redemption fee or cost, but this is willingly paid in exchange for the value that having funds with an insurance company as the immediate source provides; (f) Another simple method by which funds can be laundered is by arranging for excessive numbers or excessively high value of insurance reimbursements by cheques or wire transfers to be made; (g) A money launderer may well own legitimate assets or businesses as well as the illegal enterprise. In this method, the launderer may arrange for insurance of the legitimate assets and accidentally, but on a recurring basis, significantly overpay his premiums and request a refund for the excess. Often, the person does so in the belief that his relationship with his representative at the company is such that the representative will be unwilling to confront a customer who is both profitable to the company and important to his own success; (h) There are several cases where the early cancellation of policies with return of premium has been used to launder money. This has occurred where there have been: (i) A number of policies entered into by the same insurer/intermediary for small amounts and then cancelled at the same time; (ii) Return premium being credited to an account different from the original account; (iii) Requests for return premiums in currencies different to the original premium; and (iv) Regular purchase and cancellation of policies; (i) The overpayment of premium is more likely to be relevant to an insurance broker rather than an insurer. However, the overpayment of premium, has in the past, been used as a method of money laundering. Underwriters should be especially vigilant where: (i) The overpayment is over a certain size (say US$10,000 or equivalent); (ii) The request to refund the excess premium was to a third party; (iii) The assured is in a jurisdiction associated with money laundering; and (iv) Where the size or regularity of overpayments is suspicious; and (j) High brokerage can be used to pay off third parties unrelated to the insurance contract. This often coincides with the example of unusual premium routes. October 2005 Page 3 of 6

Cancellation and Assignment Examples of cancellation and assignment-related suspicious transactions include: (a) Assignment of policies to apparently unrelated third parties; (b) Early cancellation of policies with return of premium, with no discernible purpose or in circumstances which appear unusual; and (c) A number of policies entered into by the same insurer/intermediary for small amounts and then cancelled at the same time, the return of premium being credited to an account different from the original account. October 2005 Page 4 of 6

Claims Examples of claims-related suspicious transactions include: (a) Payment of claims to a third party without any apparent connection with the investor; (b) Abnormal settlement instructions, including payment to apparently unconnected parties or to countries in which the insured is not known to operate; (c) Strong likelihood of claims occurring, with consequently high premium; (d) Claims paid to persons other than the insured; (e) Claims which, while appearing legitimate, occur with abnormal regularity; (f) Regular small claims within premium limit; (g) Treaty reinsurances with high incidence of small claims; (h) Regular reinsurance claims paid overseas to third parties; (i) Recent change of ownership/assignment of policies just prior to a loss; and (j) Abnormal loss ratios for the nature and class of risk bound under a binding authority. October 2005 Page 5 of 6

Reinsurance Business Examples of reinsurance business-related suspicious transactions include: (a) Large proportion of business is reinsured (ceded) to a reinsurer: (i) Who is unrated or whose security is otherwise questionable; (ii) Who is located in a country which is identified by the FATF as being noncooperative in combating money laundering or about which the FATF has issued a Recommendation 21 press release; or (iii) Who is not generally regarded as a market for the class of business concerned; (b) Request for fronting business by a non-resident insurer or reinsurer, where the business is abnormal or suspicious in terms of: (i) The volume of business reinsured; (ii) The unusual nature of the risks; (iii) The lack of underwriting information; or (iv) The business appears to be written on terms which are not commercial or imprudent in relation to the underlying claims data. (c) Reinsurance Business ceded which: (i) Is abnormal in its pattern, amount or nature; (ii) Is ceded from an insurer who is located in a country which (i) is identified by the FATF as being non-cooperative in combating money laundering (ii) about which the FATF has issued a Recommendation 21 press release; (iii) Relates to a single reinsured person, where the ceding company, on enquiry, cannot provide a satisfactory explanation for the rationale of the transaction; or (iv) Is irregular, from year to year, in the pattern of business ceded (in a manner that is abnormal from industry practice). October 2005 Page 6 of 6