Life Insurer or Broker
Life Insurer or Broker
Recognizing unusual transactions
As a life insurer or broker, you are familiar with the practices within your line of business. Whether a transaction is considered unusual depends largely on your professional judgment. Your judgment is consistent with what is considered unusual within your profession. In addition to your judgment, there are situations that are unusual by nature and should therefore be reported.
If a situation arises as described in the examples below (not exhaustive), this is a reason to further examine whether the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses. It is not necessary to determine with certainty that the above-mentioned crimes have been committed. You merely need to have an assumption that the transaction can be related to one of these crimes.
If you believe that the transaction could be related to money laundering, terrorist financing, and/or associated predicate offenses, you are required to report this under the subjective indicator.
Red flags – Life insurer or broker
- The insurance contract differs significantly from what was or may be expected from the policyholder, considering all circumstances (based on income, profession, and previously concluded insurance contracts). In other words: the concluded insurance contract for the policyholder is not usual
- The policyholder accepts very unfavorable terms and conditions that are not related to his or the beneficiary’s health or age
- An (actual) insured interest cannot be provided
- The policyholder has, in a certain period, taken out several purchase policies against cash payment with this service provider through an intermediary or through mediation
- The first premium or single premium payment was made through a foreign bank account
