Tin Protekshon ora reportá? Is there protection when report?

1. Tin Protekshon ora reportá? Is there protection when report? by Melissa Balootje June 23, 2011

2. Presentation Overview • The importance • Compliance Requirements • The results • Conclusions • Recommendations Life Insurance & Intermediaries Compliance Survey

3. The importance • Global financial system is becoming more vulnerable. • There is different ways to launder money in Insurance Industry. • Money launderers and Terrorists affects the local economy and may scare away the honest investor. • The insurance industry must recognized their responsibility towards combating ML & TF. Life Insurance & Intermediaries Compliance Survey

4. Compliance Requirements Life Insurance & Intermediaries Compliance Survey

5. Requirement: Written Policies Life Insurance & Intermediaries Compliance Survey

6. Written Policies • Each insurance company should have a formal policy in place that explains the company commitment to combat ML and TF. • The policy must include statements concerning the implementation of an internal formal system to identify, control, detect and report unusual transactions. • Companies should also have a compliance officer in place to be responsible for the implementation and control of the policies. Life Insurance & Intermediaries Compliance Survey

7. More Companies have implemented a policy compared to Intermediaries Result: Written Policies Life Insurance & Intermediaries Compliance Survey

8. Requirement: Awareness Raising & Training Life Insurance & Intermediaries Compliance Survey

9. Awareness Raising & Training • Companies should screen their employees for eventual criminal records, to ensure that that their companies are performing at high ethical standards. • It is very important that the employees of the companies receive trainings programs concerning susceptible transactions listed in the National Decree containing general actions and the indicators for unusual transactions Life Insurance & Intermediaries Compliance Survey

10. Awareness Raising & Training Continue • It will be necessary to make planning for refreshment training at regular periods to ensure that the staff does not forget their responsibilities and they are updated on current and new developments in the sector of money laundering and terrorist financing. Life Insurance & Intermediaries Compliance Survey

11. Result: Awareness and Training Life Insurance & Intermediaries Compliance Survey

12. Requirement: Customer Due Diligence Life Insurance & Intermediaries Compliance Survey

13. Customer Due Diligence Companies have the obligation to determine the true identity of employees and customers, before entering into insurance contracts. It is important for the companies that the data or information collected is up-to-date and relevant. An identity card issued by local authorities, passport, and driver’s license are some of the documents that are acceptable by identifying a resident and non-resident customer. Life Insurance & Intermediaries Compliance Survey

14. Result: Customer Due Diligence Companies opinion does diver w.r.t. Customer Due Diligence Life Insurance & Intermediaries Compliance Survey

15. Compliance Requirements Life Insurance & Intermediaries Compliance Survey

16. Reporting System • Companies should ensure to report its suspicion quickly to the Financial Intelligence Unit. • All institutions should develop special programs and policies to select objectively defined unusual transactions. • Moreover, management must provide its staff with specific guidelines and training to recognize and document adequately the unusual transactions based on especially the subjective indicators. • Measures should be taken to protect the staff who has report any suspicion in a good faith. Life Insurance & Intermediaries Compliance Survey

17. Result: Reporting System Life Insurance & Intermediaries Compliance Survey

18. Result: Reporting System Continue Most companies never reported any unusual transaction Life Insurance & Intermediaries Compliance Survey

19. Compliance Requirements Life Insurance & Intermediaries Compliance Survey

20. Record Keeping System • Insurance companies should ensure that all necessary records on transaction and customer identification, both local and international, should be maintained for at least five years. Such records must be kept in order to permit a reconstruction of individual transactions. Life Insurance & Intermediaries Compliance Survey

21. Result: Record Keeping System Record Keeping System well applied by both parties Life Insurance & Intermediaries Compliance Survey

22. Relationship Insurance Companies and Intermediaries Insurance Industry and Central bank Life Insurance & Intermediaries Compliance Survey

23. Result: Relationship Life Insurance & Intermediaries Compliance Survey

24. To Conclude…… • All Insurances companies and most Intermediaries comply with rules and regulations. • Intermediaries do not apply all the applicable steps w.r.t. Customer Due Diligence. They are not always interested in identifying customers. • Companies confused when and how to report an unusual transaction. • There is a lack of training provided by companies to their staff. • Record Keeping System was the only method well implemented. Life Insurance & Intermediaries Compliance Survey

25. Recommendations • Established a consistent approach of customer identification • Reporting of suspicious/unusual transactions • More training for insurance companies and intermediaries • Further research Life Insurance & Intermediaries Compliance Survey

26. Thank you for your attention! Life Insurance & Intermediaries Compliance Survey