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Anti Money Laundering
and
Know Your Customer
Money-laundering
Engaging in processes or activities related to the proceeds of crime, such as concealment, possession, acquisition,
use; Projecting as untainted property, or claiming as untainted property, directly or indirectly, or knowingly
assisting, being a party to, or being involved in such processes or activities, constitutes money-laundering.
1
Placement
•The launderer
introduces illegally
acquired money by
breaking it in
smaller sums into
the financial
system.
•The aim is to
remove cash from
the location of
acquisition to avoid
detection from the
enforcement
authorities.
2
Layering
•Layers are created
by moving the
proceeds through a
complex web of
financial
transactions to
disassociate the
illegal monies from
the source of the
crime and conceal
any trail of source
and ownership.
3
Integration
•Illegally acquired
money is cleaned
and integrated into
the financial system
making it appear to
have been legally
earned.
•The launderer
invests the funds
into real estate,
luxury assets or
business ventures.
What constitutes a Transaction
Purchase & Sale Loan & Pledge Gift Transfer & delivery
1
Opening of an
account whether
in cash or by
cheque, payment
order or other
instruments or by
electronic or
other non-
physical means
2
The use of a
safety deposit box
or any other form
of safe deposit
3
Entering into any
fiduciary
relationship
4
Any payment
made or received
in whole or in part
of any contractual
or other legal
obligation
5
Any payment
made in respect
of playing games
of chance for cash
or kind including
such activities
associated with
casino.
6
Establishing or
creating a legal
person or legal
arrangement.
Regulatory
Framework
The Prevention of Money Laundering Act (PMLA) & its rules forms the core of the legal
framework to combat money laundering in India
IRDAI has issued Master Guidelines on AML applicable to General Insurance companies on
August 1,2022.
Punishment for the offence of Money Laundering as per Section 4 of PMLA Rigorous
imprisonment for a term which shall not be less than three years, but which may extend to
seven years and fine (no limit).
Financial Action Task Force (FATF): is an inter-governmental body that sets broad standards,
policies to combat money laundering and terrorist financing.
Financial Intelligence Unit of India (FIU-IND) is the central national agency responsible for
receiving, processing, analysing and disseminating information relating to suspect financial
transactions
The Ministry of External Affairs examines requests made by foreign countries to UAPA and in
turn forward the list after due examination to Insurance Companies where Name Screening
takes place and steps to freeze the accounts is followed.
Insurers shall go beyond FATF Statements and consider publicly available information when
identifying countries which do not apply FATF recommendations.
UN Security Council (UNSC) : UNSC 1267 . Section 51A of Unlawful Activities Prevention Act,
1957 authorizes Central Govt. to freeze, seize and/or attach funds of individuals/ entities
engaged in terrorist activities .
What constitutes a
suspicious
transaction under
PMLA
Suspicious transaction
Specified or attempted
transaction whether or not
made in cash
Proceeds of an offence
Under unusual or
unjustified circumstances
No economic rationale or
bona fide purpose
involves financing of the
activities relating to
terrorism
Transaction involving funds
linked or related to terrorist
or terrorist organisation or
those who finance or are
attempting to finance for
terrorism & terrorist acts
What to Report?
Cash transactions worth at least INR ten lakh or the equivalent in another currency
All related sequence of cash transactions that are each individually priced at less than Rs. 10 lakh.
Any sequence of cash transactions in equivalent foreign currency that occurred within a month and whose monthly aggregate
exceeded Rs. 10 lakh in foreign currency
Any transactions where non-profit organizations receive receipts valued over ten lakh rupees or its equivalent in foreign
currency"
Any cash transactions through forged or counterfeit currency or bank notes or where any forgery of valuable securities or
documents has occurred, which has enabled the transaction.
All suspicious transactions whether made in cash or other wise
Any cross-border wire transfers valued at least five lakh rupees or its equivalent in foreign currency & If the origin and
destination is India
Any buying or selling of real estate valued at fifty lakh rupees or more, which is recorded by the reporting entity, as applicable."
Every reporting entity shall maintain for a period of 5 years
after the business relationship / account has terminated.
Actions for noncompliance
Actions for Non-Compliance
Warning Notice
Directions to comply with
specific instructions
Directions to send reports on
the measures undertaken
Monetary penalty not less
than ten thousand rupees up
to one lakh rupees for each
failure.
Know Your Customer (KYC) Norms
Identify and verify Juridical persons legal status through various documents
The name,
legal form, proof of existence,
Powers that regulate and bind
the juridical persons,
Address of the registered
office/ main place of business
Authorized individual person(s)
acting on behalf of client
Ascertaining Beneficial
Owner(s)
Ensure contracts are not anonymous or fictitious.
Determine the identity of customer(s).
Know Your Customer (KYC) Norms
•Aadhaar based KYC through Online and Offline Authentication Or
•Digital KYC as per PML Rules Or
•Video Based Identification Process as consent based alternate method of establishing the customer's identity, Or
•By using „KYC identifier‟ allotted to the client by the CKYCR Or
•By using Officially Valid documents AND
•PAN/Form 60 (wherever applicable) and any other documents as may be required by the insurer
Perform KYC process by any of the following methods:
Group Insurance: KYC of Master Policyholders shall be collected and should contain details of
all the individual members covered.
Customer information should be collected from all relevant sources, including from
agents/intermediaries.
Avoid insuring assets bought out of illegal funds.
Ensure insurance premium is not be disproportionate to income/ asset.
File a Suspicious Transaction Report as per the PML Rules / guidelines issued by IRDAI
Client Due
Diligence (CDD)
New Customer
• Client due diligence must be done
at the time of commencement of
account-based relationship.
1
Existing Customer
•Periodic Due diligence based on
previously obtained data.
•Non-Availability of KYC
• Low Risk Customer : conduct KYC
within 2 years
•High Risk Customer - within 1 year
for.
• PAN/Form 60 from clients where
premiums are greater then 50,000.
2
Due diligence is not necessary for Payments for superannuation / gratuity
accumulations and to beneficiaries/ legal heirs / assignees in case of death benefits.
Conducting Client Due Diligence (CDD)
when additional remittances are made.
Incase of any Inconsistent change
For Claim payment , redemption / surrender/ partial withdrawal/ maturity / death/ refunds / reimbursement
For beneficiaries/ legal heirs/ assignees before pay-outs.
Frequent Free look cancellations
When an assignment is made to third party except to Banks/ FII / regulated intermediaries or Marine cargo insurance policies.
In case of suspicion of money- laundering or terrorist financing, or where there are factors to indicate a higher risk.
Sharing KYC
information with
Central KYC
Registry (CKYCR)
If client does not submit a
“KYC identifier” or
insurers should search on
CKYCR portal for details
Capture the KYC
information in the
prescribed template if KYC
identifier is not available .
File KYC records with
CKYCR within 10 days after
the commencement of
account-based
relationship.
Share details of “KYC
Identifier” with
policyholder
Upload on CKYCR in case
of verification /
Authentication by Aadhar
KYC records must be
incrementally uploaded
Update KYC data against
which “KYC identifier” are
yet to be
allotted/generated.
KYC records to be used
only for verifying the
identity or address of the
client.
KYC records cannot be
transferred to any third
party
Simplified Due Diligence (SDD)
SDD must be applied to customers that are classified as 'low risk’ and or where the aggregate
insurance premium is not more than Rs 10000/ - per annum.
SDD must be applied in case of suspicion of money laundering or terrorist
financing or where specific high-risk scenarios apply
Enhanced Due
Diligence (EDD) -
High -risk
categories and
Politically exposed
persons.
Examine
• The background and purpose of complex, unusual patterns of transactions without
any apparent economic or lawful purpose.
• Areas where the risks of money laundering or terrorist financing are higher.
• Senior Management to examine proposals of Politically Exposed Persons (PEPs)
Conduct
• Enhanced due diligence measures consistent with the risks identified.
• Appropriate risk management procedures for PEPs and customers who are close
relatives of PEPs to be laid out .
Check
• The ownership and financial position,
• Source of funds viz the assessed risk and product profile
Contracts emanating from countries with
deficient AML/CFT regime
Conduct
•Enhanced due
diligence while
taking insurance
risk exposure to
individuals/entities
connected with
countries identified
as having
deficiencies in their
AML/CFT regime.
Investigate
•Background and
purpose of Business
relationships and
transactions which
do not have
economic or visible
lawful purpose.
Inform
•Agents /
intermediaries /
employees
appropriately &
ensure compliance.
Check
•Publicly available
information when
identifying
countries which do
not or insufficiently
apply the FATF
Recommendations
Action
•Take measures
based on prior
experiences,
transaction history
or other factors on
countries
considered as high
risk from terrorist
financing or money
laundering
perspective.
Reporting & Record Keeping
Maintain records in
electronic and/or physical
form.
Furnish information to the
Director FIU-IND
Conduct due diligence
where services offered by a
third-party service
providers are utilized
Conduct audits on privacy of
the security of data ,
prevention of unauthorized
access, transmission and
encryption , Data protection
statutes.
Implement specific
procedures for retaining
internal records of
transactions both domestic
or international
Records must permit
reconstruction of individual
transactions, if necessary,
evidence for prosecution of
criminal activity.
Retain the records of
contracts, which have been
settled by claim or cancelled
for 5 years or till closure of
case
Leverage the broadest
number of data points in
implementing alert
generation systems wrt
suspicious activities.
Do not enter arrangement
with any unregulated entity
which may impair any
reporting obligations.
Monitoring of Transactions
Pay special attention to all
complex large
transactions/ patterns
which appear to have no
economic purpose.
Pay attention to
transaction that exceed
the threshold limit
specified by insurers for
class of client accounts.
All documents/ office
records/ memorandums/
clarifications pertaining to
identified transactions
shall be examined
Findings, records and
related documents shall be
made available to auditors
/IRDAI/ FIU-IND/ other
relevant Authorities.
The Principal Officer shall
monitor and ensure that
Suspicious transactions are
regularly reported to the
Director, FIU- IND.
Randomly conduct checks
on a sample of
transactions
Do not enter a contract with
those whose identity matches
with any person in the UN
sanction list ; banned entities &
those reported to have links
with terrorists or terrorist
organizations.
Check MHA website for
updated list of banned entities.
Maintain a check of
designated individuals/entities
to verify whether designated
individuals/entities are holding
any insurance policies with the
insurers.
Video Based Identification Process(VBIP)
The audio-visual
interaction shall be
triggered from the
domain of the
insurers & its
authorized persons.
Utilize VBIP to verify
PAN except where e-
PAN is provided.
Ensure the customer
/ beneficiary &
authorised person in
the video is
recognisable.
Geotag VBIP to
ensure presence in
India.
Ensure photograph &
documents match
the customer /
beneficiary present
for the VBIP.
Ensure varied
questions during
VBIP to establish the
interactions are not
pre-recorded.
Ensure XML file or
Secure QR Code, is
not older than 3 days
from the date of
carrying out VBIP.
VBIP accounts shall
be activated only
after proper
verification
Ensure VBIP is
seamless, real-time,
secured & encrypted
Check to guard
spoofing and
fraudulent
manipulation
Undertake audit and
validation of the
VBIP application.
Preserve activity log
& credentials of the
official performing
the VBIP
Freezing & Unfreezing of insurance policies of
‘designated individuals / entities’
check given
parameters.
Verify listed
individuals to
insurance policies
held by them.
Inform Central
Nodal Officer for
the UAPA
Prevent
transactions of
designated
individuals / entity
File a Suspicious
Transaction Report
(STR) with FIU-IND
Based on the
investigation an
order to freezing
of insurance
policies is issued
Freeze insurance
contracts
Individuals and entities may move an
application for unfreezing of
accounts with evidence to the
insurer.
All applications to be forwarded to
the Central Nodal Officer for the
UAPA
After investigation an order to
unfreeze insurance policies may be
issued
Insurers to unfreeze the accounts
Examples of
suspicious
transaction
Payment of
premium through
multiple cash
transactions or
multiple demand
drafts just below
the threshold of
Rs.50,000
Frequent free look
surrenders or
cancellations by
customers.
Frequent over
payment of
premiums with a
request for a
refund of the
amount overpaid.
Claims on Non-
Hypothecated
assets within one
year of purchase in
cash
Counterfeit
currency notes
found while
receipting cash
Adverse media
reports about
prospect customer
found in TV,
Newspaper or
other publications
Reluctance to
provide establish
his/her identity
proofs, Pan etc.
Fraudulent
income/ KYC
documents
Revised Red Flag
Indicators 2023
Red Flag Indicative Parameter Obligation
Any person whose name
appears on the watch list
specified by IRDA / MEA /
UNSC / MHA
1. Name of Customer
1. Screen at the time of policy
issuance / payout of any
benefit/claims
Cash transaction or demand
draft under 50 thousand
towards premium , top-ups etc
1. Mode of Receipt of
payment
2. Nature of Payment
3. Aggregation
4. Period
5. Threshold
1. Report transaction if the
aggregate number of
receipts exceed INR 5 Lakhs
in a calendar month or 75
Lakhs in a financial year
from a single proposer/
assignee /owner towards
payment of any nature
under all insurance policies
or proposals
Frequent Free Look
cancellations where premium
received via cash / demand
draft less than 50 thousand
1. Multiple Freelook
cancelations
1. Report 3 or more free look
cancellations received from
a single policyholder
amounting to refund of 1
lakh and above in a
calendar month
Revised Red Flag
Indicators 2023
Red Flag Indicative Parameter Obligation
Unusual termination of
policies and refunds where
premium received via cash
/ demand draft less than 50
thousand from a single
policyholder
1. Mode of Payment
2. Aggregation
3. Period
4. Threshold limit
5. Exclusions
1. Raise a trigger for
cancellation request of
policies amounting in excess
of 2 lakhs in a calendar
month where premium
received via cash / demand
draft less than 50 thousand
from a single policyholder
Inflated or Fraudulent
claims
1. Policy where SI is 1
crore
2. Annual premium
exceeding 1 Lakh
3. Claims on existent
assets
4. Submission of forged ,
fabricated documents
5. Complicity of insurance
intermediaries
1. Trigger Alert
Frequent Request of
change of Address
1. 3 or more request from
the same policyholders
in a Financial year
1. Trigger Alert
Revised Red Flag
Indicators 2023
Red Flag Indicative Parameter Obligation
Request for refund of over
payment of premium other
than declinature or
postponement of cover or
refunds on account of change
of plan
1. Refund of Premium
request in excess of 5
lakhs in a month or 25
lakhs in a financial year
1. Trigger Alert
2. Aggregate all policies
issued to a person
Customer frauds other than
claims - Different KYC
documents for different
policies in different persons of
names to avoid clubbing
1. Common Address, PAN ,
email id & phone
numbers
1. Conduct checks once a
month
2. Trigger an alert where
any one of the indicative
parameters is
established
Media Reports about a
customer
1. Report of an alleged
involvement of a policy
holder in a crime ,action
by tax authorities etc
1. Trigger an alert
Revised Red Flag
Indicators 2023
Red Flag Indicative Parameter Obligation
Information sought by
enforcement agencies or
Financial Regulator
Receipt of enquiry notice
about a policy holder
1. Trigger alert and provide
for information
Insurance of Marine export
policies in cases of export on
cost plus freight basis
1. Payment of premium in
cash , DD or combination
for amounts less than 50
thousand
2. Currency of claim is not
mentioned in the policy
1. Trigger an alert if 3 or
more such transaction
have occurred in a
financial year
Marine transit insurance –
while seeking settlement for
shortage of delivery at point of
import request for
reassignment of policy in favour
of Indian exporter at time of
settlement
Requests reassignment to
Indian exporter & where such
reassigned policies exceeds 5
lakhs per assignment request
1. Trigger Alert
Revised Red Flag
Indicators 2023
Red Flag Indicative Parameter Obligation
Claim settlement exceeding
10 lakhs on total loss for
non hypothecated assets
bought in cash
1. Insurance of assets
2. Non hypothecated
3. Claims received in first year of
policy
4. Claim value exceeds 10 lakhs
1. Raise an alert
Claim settlement exceeding
1 crore for non
hypothecated assets
bought in cash
1. Insurance of assets
2. Non hypothecated
3. Claims received in first year of
policy
4. Claim value exceeds 10 crore
1. Raise an alert
Suspicious profile of
customer
1. Complicated ownership structure
of company
2. Frequent changes of authorised
signatories followed by large
value top up transaction
3. Absence of documentation
4. Frequent claims under policies
5. Frequent change of nominee /
assignee
1. Conduct checks once
a month and Raise an
alert
2. Premium of 2 lakhs
paid on login/ renewal
Revised Red Flag
Indicators 2023
Red Flag Indicative Parameter Obligation
Policies issued to entities /
persons whoa are
barred/disqualified by
financial sector regulators
/MCA
1. Payments made by
persons/
directors/companies in
any mode for 5 lakhs or
more
1. Conduct monthly checks
and raise an alert
Thank You
The information contained herein is of a general nature and is not intended to address the circumstances of any individual or entity.
Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as
of the date it is received or that it will continue to be accurate in the future. No one should act on such information without
appropriate professional advice after a thorough examination of the situation. “Master Guidelines on Anti-Money Laundering/
Counter Financing of Terrorism (AML/CFT). This report is the property of the Finexure Consulting , Bangalore. The reproduction and
distribution of this material is forbidden without express written permission from Finexure. For more information write to us at
connect@finexure.com

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Anti Money Laundering & know client.pptx

  • 2. Money-laundering Engaging in processes or activities related to the proceeds of crime, such as concealment, possession, acquisition, use; Projecting as untainted property, or claiming as untainted property, directly or indirectly, or knowingly assisting, being a party to, or being involved in such processes or activities, constitutes money-laundering. 1 Placement •The launderer introduces illegally acquired money by breaking it in smaller sums into the financial system. •The aim is to remove cash from the location of acquisition to avoid detection from the enforcement authorities. 2 Layering •Layers are created by moving the proceeds through a complex web of financial transactions to disassociate the illegal monies from the source of the crime and conceal any trail of source and ownership. 3 Integration •Illegally acquired money is cleaned and integrated into the financial system making it appear to have been legally earned. •The launderer invests the funds into real estate, luxury assets or business ventures.
  • 3. What constitutes a Transaction Purchase & Sale Loan & Pledge Gift Transfer & delivery 1 Opening of an account whether in cash or by cheque, payment order or other instruments or by electronic or other non- physical means 2 The use of a safety deposit box or any other form of safe deposit 3 Entering into any fiduciary relationship 4 Any payment made or received in whole or in part of any contractual or other legal obligation 5 Any payment made in respect of playing games of chance for cash or kind including such activities associated with casino. 6 Establishing or creating a legal person or legal arrangement.
  • 4. Regulatory Framework The Prevention of Money Laundering Act (PMLA) & its rules forms the core of the legal framework to combat money laundering in India IRDAI has issued Master Guidelines on AML applicable to General Insurance companies on August 1,2022. Punishment for the offence of Money Laundering as per Section 4 of PMLA Rigorous imprisonment for a term which shall not be less than three years, but which may extend to seven years and fine (no limit). Financial Action Task Force (FATF): is an inter-governmental body that sets broad standards, policies to combat money laundering and terrorist financing. Financial Intelligence Unit of India (FIU-IND) is the central national agency responsible for receiving, processing, analysing and disseminating information relating to suspect financial transactions The Ministry of External Affairs examines requests made by foreign countries to UAPA and in turn forward the list after due examination to Insurance Companies where Name Screening takes place and steps to freeze the accounts is followed. Insurers shall go beyond FATF Statements and consider publicly available information when identifying countries which do not apply FATF recommendations. UN Security Council (UNSC) : UNSC 1267 . Section 51A of Unlawful Activities Prevention Act, 1957 authorizes Central Govt. to freeze, seize and/or attach funds of individuals/ entities engaged in terrorist activities .
  • 5. What constitutes a suspicious transaction under PMLA Suspicious transaction Specified or attempted transaction whether or not made in cash Proceeds of an offence Under unusual or unjustified circumstances No economic rationale or bona fide purpose involves financing of the activities relating to terrorism Transaction involving funds linked or related to terrorist or terrorist organisation or those who finance or are attempting to finance for terrorism & terrorist acts
  • 6. What to Report? Cash transactions worth at least INR ten lakh or the equivalent in another currency All related sequence of cash transactions that are each individually priced at less than Rs. 10 lakh. Any sequence of cash transactions in equivalent foreign currency that occurred within a month and whose monthly aggregate exceeded Rs. 10 lakh in foreign currency Any transactions where non-profit organizations receive receipts valued over ten lakh rupees or its equivalent in foreign currency" Any cash transactions through forged or counterfeit currency or bank notes or where any forgery of valuable securities or documents has occurred, which has enabled the transaction. All suspicious transactions whether made in cash or other wise Any cross-border wire transfers valued at least five lakh rupees or its equivalent in foreign currency & If the origin and destination is India Any buying or selling of real estate valued at fifty lakh rupees or more, which is recorded by the reporting entity, as applicable." Every reporting entity shall maintain for a period of 5 years after the business relationship / account has terminated.
  • 7. Actions for noncompliance Actions for Non-Compliance Warning Notice Directions to comply with specific instructions Directions to send reports on the measures undertaken Monetary penalty not less than ten thousand rupees up to one lakh rupees for each failure.
  • 8. Know Your Customer (KYC) Norms Identify and verify Juridical persons legal status through various documents The name, legal form, proof of existence, Powers that regulate and bind the juridical persons, Address of the registered office/ main place of business Authorized individual person(s) acting on behalf of client Ascertaining Beneficial Owner(s) Ensure contracts are not anonymous or fictitious. Determine the identity of customer(s).
  • 9. Know Your Customer (KYC) Norms •Aadhaar based KYC through Online and Offline Authentication Or •Digital KYC as per PML Rules Or •Video Based Identification Process as consent based alternate method of establishing the customer's identity, Or •By using „KYC identifier‟ allotted to the client by the CKYCR Or •By using Officially Valid documents AND •PAN/Form 60 (wherever applicable) and any other documents as may be required by the insurer Perform KYC process by any of the following methods: Group Insurance: KYC of Master Policyholders shall be collected and should contain details of all the individual members covered. Customer information should be collected from all relevant sources, including from agents/intermediaries. Avoid insuring assets bought out of illegal funds. Ensure insurance premium is not be disproportionate to income/ asset. File a Suspicious Transaction Report as per the PML Rules / guidelines issued by IRDAI
  • 10. Client Due Diligence (CDD) New Customer • Client due diligence must be done at the time of commencement of account-based relationship. 1 Existing Customer •Periodic Due diligence based on previously obtained data. •Non-Availability of KYC • Low Risk Customer : conduct KYC within 2 years •High Risk Customer - within 1 year for. • PAN/Form 60 from clients where premiums are greater then 50,000. 2 Due diligence is not necessary for Payments for superannuation / gratuity accumulations and to beneficiaries/ legal heirs / assignees in case of death benefits.
  • 11. Conducting Client Due Diligence (CDD) when additional remittances are made. Incase of any Inconsistent change For Claim payment , redemption / surrender/ partial withdrawal/ maturity / death/ refunds / reimbursement For beneficiaries/ legal heirs/ assignees before pay-outs. Frequent Free look cancellations When an assignment is made to third party except to Banks/ FII / regulated intermediaries or Marine cargo insurance policies. In case of suspicion of money- laundering or terrorist financing, or where there are factors to indicate a higher risk.
  • 12. Sharing KYC information with Central KYC Registry (CKYCR) If client does not submit a “KYC identifier” or insurers should search on CKYCR portal for details Capture the KYC information in the prescribed template if KYC identifier is not available . File KYC records with CKYCR within 10 days after the commencement of account-based relationship. Share details of “KYC Identifier” with policyholder Upload on CKYCR in case of verification / Authentication by Aadhar KYC records must be incrementally uploaded Update KYC data against which “KYC identifier” are yet to be allotted/generated. KYC records to be used only for verifying the identity or address of the client. KYC records cannot be transferred to any third party
  • 13. Simplified Due Diligence (SDD) SDD must be applied to customers that are classified as 'low risk’ and or where the aggregate insurance premium is not more than Rs 10000/ - per annum. SDD must be applied in case of suspicion of money laundering or terrorist financing or where specific high-risk scenarios apply
  • 14. Enhanced Due Diligence (EDD) - High -risk categories and Politically exposed persons. Examine • The background and purpose of complex, unusual patterns of transactions without any apparent economic or lawful purpose. • Areas where the risks of money laundering or terrorist financing are higher. • Senior Management to examine proposals of Politically Exposed Persons (PEPs) Conduct • Enhanced due diligence measures consistent with the risks identified. • Appropriate risk management procedures for PEPs and customers who are close relatives of PEPs to be laid out . Check • The ownership and financial position, • Source of funds viz the assessed risk and product profile
  • 15. Contracts emanating from countries with deficient AML/CFT regime Conduct •Enhanced due diligence while taking insurance risk exposure to individuals/entities connected with countries identified as having deficiencies in their AML/CFT regime. Investigate •Background and purpose of Business relationships and transactions which do not have economic or visible lawful purpose. Inform •Agents / intermediaries / employees appropriately & ensure compliance. Check •Publicly available information when identifying countries which do not or insufficiently apply the FATF Recommendations Action •Take measures based on prior experiences, transaction history or other factors on countries considered as high risk from terrorist financing or money laundering perspective.
  • 16. Reporting & Record Keeping Maintain records in electronic and/or physical form. Furnish information to the Director FIU-IND Conduct due diligence where services offered by a third-party service providers are utilized Conduct audits on privacy of the security of data , prevention of unauthorized access, transmission and encryption , Data protection statutes. Implement specific procedures for retaining internal records of transactions both domestic or international Records must permit reconstruction of individual transactions, if necessary, evidence for prosecution of criminal activity. Retain the records of contracts, which have been settled by claim or cancelled for 5 years or till closure of case Leverage the broadest number of data points in implementing alert generation systems wrt suspicious activities. Do not enter arrangement with any unregulated entity which may impair any reporting obligations.
  • 17. Monitoring of Transactions Pay special attention to all complex large transactions/ patterns which appear to have no economic purpose. Pay attention to transaction that exceed the threshold limit specified by insurers for class of client accounts. All documents/ office records/ memorandums/ clarifications pertaining to identified transactions shall be examined Findings, records and related documents shall be made available to auditors /IRDAI/ FIU-IND/ other relevant Authorities. The Principal Officer shall monitor and ensure that Suspicious transactions are regularly reported to the Director, FIU- IND. Randomly conduct checks on a sample of transactions Do not enter a contract with those whose identity matches with any person in the UN sanction list ; banned entities & those reported to have links with terrorists or terrorist organizations. Check MHA website for updated list of banned entities. Maintain a check of designated individuals/entities to verify whether designated individuals/entities are holding any insurance policies with the insurers.
  • 18. Video Based Identification Process(VBIP) The audio-visual interaction shall be triggered from the domain of the insurers & its authorized persons. Utilize VBIP to verify PAN except where e- PAN is provided. Ensure the customer / beneficiary & authorised person in the video is recognisable. Geotag VBIP to ensure presence in India. Ensure photograph & documents match the customer / beneficiary present for the VBIP. Ensure varied questions during VBIP to establish the interactions are not pre-recorded. Ensure XML file or Secure QR Code, is not older than 3 days from the date of carrying out VBIP. VBIP accounts shall be activated only after proper verification Ensure VBIP is seamless, real-time, secured & encrypted Check to guard spoofing and fraudulent manipulation Undertake audit and validation of the VBIP application. Preserve activity log & credentials of the official performing the VBIP
  • 19. Freezing & Unfreezing of insurance policies of ‘designated individuals / entities’ check given parameters. Verify listed individuals to insurance policies held by them. Inform Central Nodal Officer for the UAPA Prevent transactions of designated individuals / entity File a Suspicious Transaction Report (STR) with FIU-IND Based on the investigation an order to freezing of insurance policies is issued Freeze insurance contracts Individuals and entities may move an application for unfreezing of accounts with evidence to the insurer. All applications to be forwarded to the Central Nodal Officer for the UAPA After investigation an order to unfreeze insurance policies may be issued Insurers to unfreeze the accounts
  • 20. Examples of suspicious transaction Payment of premium through multiple cash transactions or multiple demand drafts just below the threshold of Rs.50,000 Frequent free look surrenders or cancellations by customers. Frequent over payment of premiums with a request for a refund of the amount overpaid. Claims on Non- Hypothecated assets within one year of purchase in cash Counterfeit currency notes found while receipting cash Adverse media reports about prospect customer found in TV, Newspaper or other publications Reluctance to provide establish his/her identity proofs, Pan etc. Fraudulent income/ KYC documents
  • 21. Revised Red Flag Indicators 2023 Red Flag Indicative Parameter Obligation Any person whose name appears on the watch list specified by IRDA / MEA / UNSC / MHA 1. Name of Customer 1. Screen at the time of policy issuance / payout of any benefit/claims Cash transaction or demand draft under 50 thousand towards premium , top-ups etc 1. Mode of Receipt of payment 2. Nature of Payment 3. Aggregation 4. Period 5. Threshold 1. Report transaction if the aggregate number of receipts exceed INR 5 Lakhs in a calendar month or 75 Lakhs in a financial year from a single proposer/ assignee /owner towards payment of any nature under all insurance policies or proposals Frequent Free Look cancellations where premium received via cash / demand draft less than 50 thousand 1. Multiple Freelook cancelations 1. Report 3 or more free look cancellations received from a single policyholder amounting to refund of 1 lakh and above in a calendar month
  • 22. Revised Red Flag Indicators 2023 Red Flag Indicative Parameter Obligation Unusual termination of policies and refunds where premium received via cash / demand draft less than 50 thousand from a single policyholder 1. Mode of Payment 2. Aggregation 3. Period 4. Threshold limit 5. Exclusions 1. Raise a trigger for cancellation request of policies amounting in excess of 2 lakhs in a calendar month where premium received via cash / demand draft less than 50 thousand from a single policyholder Inflated or Fraudulent claims 1. Policy where SI is 1 crore 2. Annual premium exceeding 1 Lakh 3. Claims on existent assets 4. Submission of forged , fabricated documents 5. Complicity of insurance intermediaries 1. Trigger Alert Frequent Request of change of Address 1. 3 or more request from the same policyholders in a Financial year 1. Trigger Alert
  • 23. Revised Red Flag Indicators 2023 Red Flag Indicative Parameter Obligation Request for refund of over payment of premium other than declinature or postponement of cover or refunds on account of change of plan 1. Refund of Premium request in excess of 5 lakhs in a month or 25 lakhs in a financial year 1. Trigger Alert 2. Aggregate all policies issued to a person Customer frauds other than claims - Different KYC documents for different policies in different persons of names to avoid clubbing 1. Common Address, PAN , email id & phone numbers 1. Conduct checks once a month 2. Trigger an alert where any one of the indicative parameters is established Media Reports about a customer 1. Report of an alleged involvement of a policy holder in a crime ,action by tax authorities etc 1. Trigger an alert
  • 24. Revised Red Flag Indicators 2023 Red Flag Indicative Parameter Obligation Information sought by enforcement agencies or Financial Regulator Receipt of enquiry notice about a policy holder 1. Trigger alert and provide for information Insurance of Marine export policies in cases of export on cost plus freight basis 1. Payment of premium in cash , DD or combination for amounts less than 50 thousand 2. Currency of claim is not mentioned in the policy 1. Trigger an alert if 3 or more such transaction have occurred in a financial year Marine transit insurance – while seeking settlement for shortage of delivery at point of import request for reassignment of policy in favour of Indian exporter at time of settlement Requests reassignment to Indian exporter & where such reassigned policies exceeds 5 lakhs per assignment request 1. Trigger Alert
  • 25. Revised Red Flag Indicators 2023 Red Flag Indicative Parameter Obligation Claim settlement exceeding 10 lakhs on total loss for non hypothecated assets bought in cash 1. Insurance of assets 2. Non hypothecated 3. Claims received in first year of policy 4. Claim value exceeds 10 lakhs 1. Raise an alert Claim settlement exceeding 1 crore for non hypothecated assets bought in cash 1. Insurance of assets 2. Non hypothecated 3. Claims received in first year of policy 4. Claim value exceeds 10 crore 1. Raise an alert Suspicious profile of customer 1. Complicated ownership structure of company 2. Frequent changes of authorised signatories followed by large value top up transaction 3. Absence of documentation 4. Frequent claims under policies 5. Frequent change of nominee / assignee 1. Conduct checks once a month and Raise an alert 2. Premium of 2 lakhs paid on login/ renewal
  • 26. Revised Red Flag Indicators 2023 Red Flag Indicative Parameter Obligation Policies issued to entities / persons whoa are barred/disqualified by financial sector regulators /MCA 1. Payments made by persons/ directors/companies in any mode for 5 lakhs or more 1. Conduct monthly checks and raise an alert
  • 27. Thank You The information contained herein is of a general nature and is not intended to address the circumstances of any individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the situation. “Master Guidelines on Anti-Money Laundering/ Counter Financing of Terrorism (AML/CFT). This report is the property of the Finexure Consulting , Bangalore. The reproduction and distribution of this material is forbidden without express written permission from Finexure. For more information write to us at connect@finexure.com