aml presentation & kyc ver 1.9

Anti Money

Laundering

and

Know Your

Customer

11/15/15 1Sales Training -AML Presentation Ver 1.9

2

Anti Money Laundering Regulations

Process of Money Laundering

Obligation of SUD Life

Procedure for identification of Beneficial Ownership

Know Your Customer (KYC)

Impact of Anti Money Laundering

Moral Hazard Report (MHR)

Enhanced Due Diligence

Suspicious Transactions

Exceptions to AML

What is FATF?

KYC Requirements

SummaryRisk Assessment

Agenda

11/15/15 Sales Training -AML Presentation Ver 1.9

What is Money Laundering ?

3

Money Laundering is defined as movement of illegally acquired cash through financial systems so that it appears to be legally acquired.

• Money Laundering is the processing of DIRTY MONEY, in order to disguise their illegal origin.

• Dirty Money are proceeds derived from criminal conduct.

• Criminals want the money to look like it came from a legitimate source.


In India, Anti Money Laundering (AML)

measures are controlled through “The

Prevention of Money Laundering Act,

2002”, which was brought in force with

effect from 1st July 2005.

IRDA has made the AML guidelines

mandatory for all insurance companies

with effect from 1st August 2006.

FIU-IND (Financial Intelligence Unit) is a

govt. set up responsible for receiving,

processing, analyzing and disseminating

information relating to suspicious financial/

cash transactions.

Compliance to these AML norms is required

by SUD Life.4

Anti Money Laundering Regulations


5

Process of Money Laundering


Placement: This is the first stage where criminals dispose off physical cash proceeds derived from illegal activities. Some methods used here are: small but regular deposits or investments.

For example: a customer taking multiple insurance policies for cash premium under Rs. 50,000.

Process of Money Laundering (Continued...)

Placement:

6 611/15/15 Sales Training -AML Presentation Ver 1.9

Layering: This stage concentrates on separation of proceeds from criminal activity through the use of various layers of monetary transactions. These layers are aimed at clearing away the audit trails, disguise the origin and maintain anonymity for people behind the transactions.

For example: frequent free-look cancellation, frequent top up premiums, using multiple bank accounts, intermediaries and countries to disguise the origin.


Layering:

7 711/15/15 Sales Training -AML Presentation Ver 1.9

Integration: At this stage, the laundered proceeds are placed back into the economy in such a way, that they re-enter the financial system appearing to be normal business funds (legitimate funds). For example: investment products, fixed assets, etc.

Integration:



9


PlacementLaye

ring

Integration

Let’s Recap….


10

Obligation of SUD Life

As directed by the regulator, u/s 12 of the PMLA, SUD Life

has an obligation to verify identity of its clients and beneficial

owner, report transaction and maintain records.

This covers:

• Maintenance of records of all transactions.

• Maintenance in such a way that reconstruction of individual transactions is possible at a later date.

• Reporting of attempted transactions.

• The obligation of verifying and identifying the clients, including the beneficial owners.

• Time limit for maintenance of records for reportable transactions and identity of clients

and beneficial owners. The obligation for maintenance of records of identity is linked to

end of business relationship or closure of accounts. Note: Beneficial Owner as per PLMA is ‘the natural person on whose

behalf the transaction is being conducted and includes a person who

exercises ultimate effective control over juridical person.

Process for identifying beneficial owner is covered in subsequent slides.11/15/15 Sales Training -AML Presentation Ver 1.9

AML/ KYC Requirements

1) New Business 1) New

Business

AML/ KYC guidelines apply for all proposals logged

in from 1st August 2006, including cases where

customer has previous policies with us.

AML/ KYC will be applicable at the following

stages :

2) Policy

Servicing

2) Policy

Servicing

3) Claims

3) Claims


AML/ KYC Grid (Based annualized premium)

• Where annualized premium is equal to or more than Rs. 50,000, it is mandatory to submit PAN OR

• Declaration for PAN exemption in specified format for NRI’s / Agriculturists (via Form 60 / 61).

• If premium payer is different from Life to be Assured (e.g. Husband paying for Wife), KYC of the Life to be Assured and the income details of Premium Payer need to be furnished.


12

• Proposer’s AML / KYC documents are required where the life to be assured is a minor or housewife or premium remitter is other than life assured.


In case of new contracts, KYC should be done before the issue of every contract. While carrying out the KYC exercise special care to be

taken to ensure that contract is not under anonymous or under fictitious names.

SUD Life will not enter into a contract with a customer whose identity matches with any person with known criminal background or with banned entities and those reported to have links with terrorists or terrorist organization.

Acceptance of cash (inclusive of renewal premium & top up premium) is not permitted under Bancassurance Channel. It would be acceptable only through cheque / demand draft / any other banking instrument.

Remittances of premium by cash above Rs. 50,000/- will be accepted under Agency Channel only on per transaction basis subject to customer quoting of PAN.

SUD Life shall verify the authenticity of the details of PAN so obtained. In case of customer not required to have PAN or with an agricultural income, Form 60 / 61 prescribed under Income Tax Act will be obtained.

AML/ KYC RequirementsNew Business


Top Up Premium (Amount which is paid

over and above the premium):

If Top up + Annualized regular premium (combined or

separately) is equal to or more than Rs.1 lac, proof of income is

to be submitted.

KYC is to be carried out at times when the top up remittance is

inconsistent with the customer’s profile.

Any change in the customers recorded profile that comes to

the notice of sales staff/ back office staff, which is inconsistent

with the normal and expected activity of the customer will

require KYC exercise to be taken afresh.

14

AML/KYC Requirements

Policy Servicing


Assignment (An assignment transfers the rights, title and

interest of the assignor to the assignee)

At the time of assignment, the requirements are:

Relationship with assignee

Identity proof of assignee

Address proof of assignee

If assignments are made to parties (other than parents /

spouse / children / member of a Hindu Undivided Family) or to

entities other than financial institutions; in addition to the

above, proof of insurable interest will be required.15


Policy Servicing


Address Change:

• All residential address change requests to be submitted with proof of new

address.

Redemption / Surrender:

• No payments will be allowed to 3rd parties except in cases like

superannuation / gratuity accumulations and payments to legal heirs in

case of death benefits

• Clients / agents indulging in free look cancellations (i.e. cancellation of

policy within the permitted time frame as defined in the policy document)

on multiple occasions will be monitored closely.

16

AML/ KYC RequirementsPolicy Servicing


KYC is to be carried out at the time of claim payout stage.

Along with the claim form:

Residence proof of the nominee is to be submitted.

Identity proof of the nominee is to be submitted.

All Payments exceeding Rs.10,000/- per claims should be

made through account payee cheque, electronic payment

methods such as ECS, NEFT systems approved by RBI.

17

AML/ KYC RequirementsClaims


Know Your Customer

Considering the potential threat of usage of financial services, SUD Life will make reasonable efforts to determine the true identity of all of its customers. It will also ensure that insurable interest is established in all cases where premium is paid by persons other than the person insured. In order to establish the identity of its customers, an effective procedure is put in place.

Know Your Customer

Due Diligence:


• Details of sources of funds for all policies to be obtained, where the annual premium per policy is equal to or greater than Rs. 1 lac, in a financial year.

• Mere documentation of income proof does not constitute establishing ‘source of funds’.

• Enhanced due diligence has to be carried out while ascertaining sources of funds.

• Sources of fund should be obtained through questionnaire / declarations on sources of fund / details of bank accounts etc.

• Details of sources of funds for all policies to be obtained, where the annual premium per policy is equal to or greater than Rs. 1 lac, in a financial year.

• Mere documentation of income proof does not constitute establishing ‘source of funds’.

• Enhanced due diligence has to be carried out while ascertaining sources of funds.

• Sources of fund should be obtained through questionnaire / declarations on sources of fund / details of bank accounts etc.

Enhanced Due Diligence

Source Of Fund


Some reasonable measures in carrying out detailed due diligence:

More frequent reviews of the customer’s activities / profile / transactions.

Application of additional measures like gathering information from publicly

available source or otherwise

Review of the proposal / contract by senior official.

Prohibition of acceptance of proposal from customers residing in FATF deficient

countries.

Close monitoring of cash remittances

Extra care and due diligence where Form 60 or 61 have been submitted

Cashless settlement of claims, payments directly to bankers, dealers/ repairers,

employers, claimants through NEFT/ RTGS

20

Enhanced Due Diligence Measures


Moral Hazard Report (MHR)

Advisors / Specified Persons being the front end support

and preliminary underwriters, will have to indicate any

behavioral aspects of a Customer that are found to be

suspicious at the time of their interaction in the Agent’s

Confidential Report / SP report. Depending on the Sum

Assured and profile, Moral Hazard Report from the Sales

hierarchy within SUD Life will be obtained.


Where a customer is other than individual or trust, SUD Life shall identify the beneficial owners of the customers & take reasonable measures to verify the identity of such persons through following information's.

22

Procedure for Determination of Beneficial OwnerCustomers other than individuals or trust

Customer other than Individual or Trust (Indentified basis controlling ownership interest)

Where a juridical person is a company - Ownership >25% of

shares or capital

Where a juridical person is a partnership firm - Ownership >

15% of capital or profit

Where a juridical person is a unincorporated association -

ownership > 15% of property or capital

Incase of any doubt to above or whether no person exerts

control through ownership interests, the identity of the natural

person exercising control over the juridical persons through

other means. Control through other means can be exercised

through voting rights, agreements, arrangements etc.

Where no natural person is identified above, the identity of the

relevant natural person who holds the position of senior

managing official.


23

Procedure for Determination of Beneficial Owner Continued…Customers other than individuals or trust continued… Customer is

Trust

Through the identity of the settler of the trust, the trustee, the

protector, the beneficiaries with 15% or more interest in the

trust and any other natural person exercising ultimate effective

control over the trust through a chain of control or ownership

Exceptions Where owner of controlling interest is a listed company or is a

majority owned subsidiary of such company.

Applicability • The above shall be applied for premium threshold as under :

Keyman contracts -Rs. 1 lac / policy

Partnership contracts - Rs. 2 lac / policy

Others (HUF / Trust) - Rs. 1 lac / policy

In cases of employer-employee policies, threshold laid above are as relevant to the constitution of the juridical person taking insurance contact.


Risk ClassificationSUD Life will carry out risk assessment to identify,

assess and take effective measures to mitigate its

Money Laundering and Terrorist Financing risk for

client, countries or geographic location and

products, services, transactions or delivery channel.

The risk assessment shall be documented; consider

all the relevant risk factors before determining the

level of overall risk and the appropriate level and

type of mitigation to be applied; be kept up to date;

and be available to competent authorities and self-

regulating bodies.


Risk Classification Continued …

Risk profile of product / features

High Risk (Vulnerable features):

Free Look Option

Top-up Premium

Partial Withdrawal

Single Premium Payment

Borrowing on Policy

Assignment to third parties



Risk profile of product / features

Low Risk:

Micro Insurance Products

Pure Risk Cover

Pension and Annuities contract

Group Insurance Product

Health Products

Reinsurance and Retrocession contracts.



In the context of very large base of insurance

customers and the significant differences in

the extent of risk posed by them.

IRDA has instructed all insurers to classify their

customers into different risk categories:

27

Risk Profile of the Customer

High Risk Profile Low Risk Profile



High Risk Profile:

A High Risk profile customer would typically consist of

customers who by nature of their occupation, place of

residence or any other characteristics are more

vulnerable to money laundering. Some examples of such

cases have been listed below:

Customers involved in a business that handles large amounts of cash. For example, Scrap dealers, Persons engaged in Real Estate business, businesses with a complicated ownership structure that could conceal underlying beneficiaries. Non-resident Indians and Foreign residents Politically Exposed Persons (PEPs). High Networth Individuals (HNI) (Generally, individual policyholders who pay a premium above Rs.5 lakhs per annum on all classes of Insurance) Customer’s Geographic location.



29

Politically Exposed Person (PEP)

Domestic PEPs are individuals who are or have been entrusted

domestically with prominent public functions, for example Heads of State

or of government, senior politicians, senior government, judicial or military

officials, senior executives of state owned corporations, important political

party officials. Persons who are or have been entrusted with a prominent

function by an international organization refers to members of senior

management, i.e. directors, deputy directors and members of the board or

equivalent functions. The definition of PEPs is not intended to cover

middle ranking or more junior individuals in the foregoing categories.

High Risk Profile continued…



Enhanced due diligence will be done in case of high risk

profile customer.

Proposals of high risk customers should be approved by head

underwriting.

All PEP cases (includes close relatives & where PEP is the ultimate

beneficial owner) to be approved by Sr. Management not below Head

Underwriting / Head Risk Management.

PEP MHR needs to be signed and submitted by AVP for all PEP cases.

If the ongoing risk management procedures indicate that the customer

or beneficial owner is found to be, or subsequently becomes a PEP,

senior management approval will be obtained on this business

relationship.


Risk Classification Continued…

Other Risks

Mode of premium remittances e.g. cash, banking channels, credit cards

Type of premium remittances opted: Single premium / Regular premium

Sources of premium funding, especially when it is being funded by a third party. However, underlying risks minimize in relationship between payor and insured as under:

o Close family relationships,

o Debtor-Creditor relationships,

o Employer-employee relationships

o Parent-subsidiary relation

o Consignor-consignee relation 3111/15/15 Sales Training -AML Presentation Ver 1.9

Identify High Risk Profile Customers

Mr. Ashish Parekh- A Famous Builder

Ms. Lalita Gandhi – A Youth Leader

Mr. Shahid Kumar – Senior politician

Mr. Vikas Shah – A Stationery Dealer

Ms. Jiya Rai - Actress

32



Mr. Ashish Parekh- A Famous Builder

Ms. Lalita Gandhi – A Youth Leader

Mr. Shahid Kumar – Senior politician

Check the answers…

33



Mr. Vidyadhar Sule - A Farmer

Ms. Kavita Patil – A Municipal School Teacher

Mr. Sharad Sathe – A Government Clerk

Mr. Kartik Mehera – A HNI

34

Risk Profile CustomerIdentify Low Risk Profile Customers


Mr. Vidyadhar Sule - A Farmer

Ms. Kavita Patil – A Municipal School Teacher

Mr. Sharad Sathe – A Government Clerk

Check the correct answers…

35



Regulatory Reporting


Any suspicious transactions that are identified will be

reported to the FIU-IND within 7 working days of

identification in the prescribed format.

Besides the above, employees / sales personnel will be

responsible to report any suspicious transactions that

are noticed by them to the Principal Compliance Officer

at [email protected]

37



mailto:[email protected]

Illustrative list of Suspicious Transactions, requiring further scrutiny:

Customer (including assignees, where applicable) whose identity matches with any person whose name figures in the list of banned persons and entities

Cash transactions for payment of premium and top-ups of Rs. 5 lakhs and above. Multiple DDs each denominated for less than Rs. 50,000/- Frequent free look cancellations by customers Single policy free look cancellation Assignments to unrelated parties without consideration (or inadequate consideration) Request for purchase of insurance policy considered beyond one’s apparent need Unusual termination of policies and refunds Frequent requests for change in addresses Borrowing the maximum amount under an insurance policy soon after buying it Inflated or totally fraudulent claimsOverpayment of premiums with a request for refund of the amount overpaid

38


*Note: The list is only illustrative and not exhaustive.


IRDA has mandated compulsory reporting to the FIU-IND for:

Cash Transactions: All integrally connected cash transactions

above Rs 10 lakhs in a month.

Reporting of receipts by Non-Profile Organization - All

transactions, involving receipts by non-profit organization

(either in the form of assignments and /or in the form of top-up

remittances) of value more than Rs. 10 lacs, or its equivalent in

foreign currency, should be reported to FIU-IND by 15th day of

the next succeeding month

Reporting of Counterfeit Currency / Forged Bank notes

(CCR) - All cash transactions where forged or counterfeit

currency notes or bank notes have been used as genuine and

where any forgery of a valuable security or a document has

taken place facilitating the transactions should be reported

within 7 days of identification to FIU-IND

39

Other FIU-IND Reporting


Anti Money Laundering guidelines are applicable to all

insurance business except:

Standalone medical / health insurance products

Group insurance business

AML does not apply to the above mentioned products because:

Lower risk profile of these products

Event based payouts

More stringent underwriting norms

Exceptions to AML


• FATF provides list of countries which are not compliant with FATF (Financial

Action Task Force) recommendations. These countries are termed as AML/

FATF deficient countries.

*Note: List of FATF Deficient Countries will be provided by the Compliance Team

to operations for monitoring. Such list is updated on a continuous basis. 41

The Financial Action Task Force (FATF)


List of Countries* (updated as on August 2015)

Iran Bosnia and Herzegovina

Sudan

Democratic Peoples’ Republic of Korea

(DPRK)

Ecuador Syria

Algeria Guyana Uganda

Eucador Laos and Lao PDR

Yemen

Myanmar Panama Angola

Afghanistan Papua New Guinea

Photo ID ProofPhoto ID Proof

Address ProofAddress Proof

Income ProofIncome Proof

Source of FundSource of Fund

List of acceptable KYC documents shall be covered in subsequent slides.

42

KYC Requirements


It is mandatory to establish customer’s identify in respect of all insurance contracts. Life Assured or Proposer has to sign across the photograph on the proposal form.• Passport • PAN Card • Voter’s Identity Card • Driving License • Ration Card (bearing a photograph of the Customer) • Letter from a recognized public authority or public servant verifying the

identity of the customer • Written confirmation from the banks where the prospect is a customer

• Employee identity card of a listed company or public sector company • Personal identification and certification by SUD Life employees for

identity of the prospective policyholder. • Board (e.g. SSC, HSC, SSLC, etc) or University mark sheets bearing

photo. • University mark sheet bearing photo issued to student.

It is mandatory to establish customer’s identify in respect of all insurance contracts. Life Assured or Proposer has to sign across the photograph on the proposal form.• Passport • PAN Card • Voter’s Identity Card • Driving License • Ration Card (bearing a photograph of the Customer) • Letter from a recognized public authority or public servant verifying the

identity of the customer • Written confirmation from the banks where the prospect is a customer

• Employee identity card of a listed company or public sector company • Personal identification and certification by SUD Life employees for

identity of the prospective policyholder. • Board (e.g. SSC, HSC, SSLC, etc) or University mark sheets bearing

photo. • University mark sheet bearing photo issued to student.

KYC Requirements (Continued…)

Photo ID Proof


• Employee ID cards bearing photo issued by Central or State Govt.

• Kisan credit card bearing photo

• Bank pass book bearing photo

• Defense ID card / Defense dependent's card / Ex-serviceman card bearing photo

• Identity cards bearing photo issued by professional bodies such as:

Bar Council

Indian Medical Association

Institute of Chartered Accountants of India

Institute of Company Secretaries of India

Institute of Cost & Works Accountants of India

• Senior citizen card bearing photo

• Pension ID card issued by Stat e/ Central Govt. bearing photo.

• NREGA Card issued by State govt.

• UID Card is being accepted for Address and ID proof

• Officially valid document notified by Central Govt.

The List is illustrative and not exhaustive

• Employee ID cards bearing photo issued by Central or State Govt.

• Kisan credit card bearing photo

• Bank pass book bearing photo

• Defense ID card / Defense dependent's card / Ex-serviceman card bearing photo

• Identity cards bearing photo issued by professional bodies such as:

Bar Council

Indian Medical Association

Institute of Chartered Accountants of India

Institute of Company Secretaries of India

Institute of Cost & Works Accountants of India

• Senior citizen card bearing photo

• Pension ID card issued by Stat e/ Central Govt. bearing photo.

• NREGA Card issued by State govt.

• UID Card is being accepted for Address and ID proof



KYC Requirements (Continued…)Photo ID Proof

continued…


It is mandatory to provide customer’s permanent and current address proof in respect of all insurance contracts. The address proof submitted must match with communication and / or permanent address given in the proposal form.

• Telephone bill including mobile, landline, wireless etc type of connections, not older than 6 months from the date of insurance contract.

• Letter from any recognized public authority or public servant • Credit card statement • Electricity bill • Passport • Driving License • Ration card • Valid lease agreement along with rent receipt, which is not more

than 3 months old • Employer’s certificate for residence proof. (Certificates of employers

who have in place systematic procedures for recruitment along with maintenance of mandatory records of its employees)

It is mandatory to provide customer’s permanent and current address proof in respect of all insurance contracts. The address proof submitted must match with communication and / or permanent address given in the proposal form.

• Telephone bill including mobile, landline, wireless etc type of connections, not older than 6 months from the date of insurance contract.

• Letter from any recognized public authority or public servant • Credit card statement • Electricity bill • Passport • Driving License • Ration card • Valid lease agreement along with rent receipt, which is not more

than 3 months old • Employer’s certificate for residence proof. (Certificates of employers

who have in place systematic procedures for recruitment along with maintenance of mandatory records of its employees)


Address Proof


• Current passbook (updated to previous month) & Current Statement of bank account (as downloaded) with details of permanent / present residence address.

• Written confirmation from the banks where the prospect is a customer.

• Consumer Gas connection card / book (with transactions within the last 3 months)

• Gas Bill / Gas connection letter (less than 3 months old)

• Water Tax Bill mentioning flat number or owner's name (less than 3 months old)

• Voter’s ID

• Govt. Service ID Card


• Current passbook (updated to previous month) & Current Statement of bank account (as downloaded) with details of permanent / present residence address.

• Written confirmation from the banks where the prospect is a customer.

• Consumer Gas connection card / book (with transactions within the last 3 months)

• Gas Bill / Gas connection letter (less than 3 months old)

• Water Tax Bill mentioning flat number or owner's name (less than 3 months old)

• Voter’s ID

• Govt. Service ID Card



Address Proof continued…

46



• Latest copy of Income tax assessment orders / Income Tax returns slips

• Form 16 in case of employed individual

• Salary slips from employers (within last 3 months) – For present employment of 3 months or more.

• Latest copy of Audited Company accounts

• Latest copy of Audited firm accounts and Partnership deed

• Latest copy of Audited proprietorship profit & loss account

• Latest copy of Copies of form no. 10CCAC under section 80 HHC of IT ACT 1961 for export income

• Latest copy of Income tax assessment orders / Income Tax returns slips

• Form 16 in case of employed individual

• Salary slips from employers (within last 3 months) – For present employment of 3 months or more.

• Latest copy of Audited Company accounts

• Latest copy of Audited firm accounts and Partnership deed

• Latest copy of Audited proprietorship profit & loss account

• Latest copy of Copies of form no. 10CCAC under section 80 HHC of IT ACT 1961 for export income


Income ProofForm

16

CA

Certific

ate


• Employer’s Certificate

• Appointment letter mentioning salary + salary slip - For present

employment of less than 3 months.

• Chartered Accountant's certificate

• Bank cash flow statements, pass books

• Registration certificate (RC) book for transport fleet owners

• Mandi receipt of sale of agricultural crop + Agricultural land details

& income assessments

• Agricultural Income Certificate

• Agricultural-land details & Income assessments

• Employer’s Certificate

• Appointment letter mentioning salary + salary slip - For present

employment of less than 3 months.

• Chartered Accountant's certificate

• Bank cash flow statements, pass books

• Registration certificate (RC) book for transport fleet owners

• Mandi receipt of sale of agricultural crop + Agricultural land details

& income assessments

• Agricultural Income Certificate

• Agricultural-land details & Income assessments


Income Proof continued… Form

16

CA

Certific

ate

48



49

Mr. Dayal is an owner of ‘Grand

Dine’ hotel

He has recently sold his land for Rs. 50 lacs.

He wants to buy 3 life insurance

policies of rupees 10 lacs each

(single premium) through

Bancassurance Channel.

He wants to make cash payment.

Let Us Check!Dayal’s Story


What should the company do in such cases?

Let Us Check!

50

*Note - Cash can be accepted under Agency Channel.

Accept the cash

Cash can not be accepted, has to pay through cheque or demand

draft


51

He submits IT return as

income proof and bank

statement.

As per IT return his

annual income is 10

lacs only .

He maintains an average balance

of Rs. 5,00,000 since past 6

months.

His bank statement shows an entry of

Rs. 40 lacs deposited on a

single day on his bank account 2 days before the

date of proposal of policy

Dayal’s Story (Continued) Let Us Check!


Source of fund is required where he can provide the proof of sale of landSource of fund is required where he can provide the proof of sale of land

Self declaration is to be submittedSelf declaration is to be submitted

Policy will be rejected immediatelyPolicy will be rejected immediately

In this case What can be the additional requirement can be called for?

Let Us Check!


53

Unfortunately, after 6

years, Mr. Dayal dies

due to a road accident.

His wife has claimed for the policy money.

Let Us Check!


KYC documents are required like address proof & photo ID of the

nominee.

What will be the AML & KYC requirements at this stage?

Let Us Check!

54

Nominee has to provide the relationship proof with deceased life assured along with the power

of attorney


Sales staff / field force are front line staff (preliminary underwriters) who actually

see and meet the policyholder in person.

Document information about the policyholder mostly those which are intentionally

not disclosed by the customers for. e.g. customer is an active PEP or close relative

of PEP. Such disclosures are required to be made in the Advisor Confidential

Report(ACR).

Adverse media or negative news is unfavorable information that can be found in a

variety of reference sources. The risks associated in conducting business with such

persons or companies which have an adverse media profile are many. Again since

the field force being the front line staff, they will be able to provide with such

important information about the customer in the ACR. For e.g. individual /

company is associated in criminal activity, scams, financial frauds, was sentenced

to jail / bar or currently serving for court’s hearing etc.

55

Please Do Remember !


In this session you have learnt: What is Money laundering? The process of money laundering. Know Your Customer (KYC)Money laundering regulations. The concept of know your customer. Impact of money laundering on insurance business. Different categories of risk profile of customers. Moral Hazard Report (MHR) Some of the suspicious transactions. Anti money laundering and know your customer requirements. Obligation of SUDLifeFinancial Action Task Force (FATF)Risk assessment

Summary


Disclaimer

This material belongs to the Sales Training Team of Star Union Dai-ichi Life Insurance Company Limited.

Any unauthorized use, reprint or circulation is prohibited.

For Internal Circulation Only.

Star Union Dai-ichi Life Insurance Company Limited. (Registration No. 142.), 11th Floor, Raghuleela Arcade,

IT park, Sector 30 A, Opp. Vashi Railway Station, Vashi, Navi Mumbai – 400703

Insurance is the subject matter of the solicitation.


aml presentation & kyc ver 1.9

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