Sanctions and PEP Screening for the Insurance Industry

Protecting our customers, so you can protect yours

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  • Sanctions and PEP screening for insurance brokers, insurers, reinsurers and claim management firms.
  • Multiple screening options to cover screening at quote, bind, claim, renewal and more.
  • Continual monitoring for sanctions notifications and easy re-screening.
  • Effortless screening for large volumes through bulk loading.
  • Robust due diligence checks with access to a global selection of 500+ regulatory and sanctions lists.

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Complexity of Client Screening

Financial sanctions can limit the provision of insurance. Whether you are a broker, insurer, reinsurer or a claims handler you need to know if these restrictions apply to the customers you are providing cover to.

Comprehensive sanctions screening can be complex to put in place, with many different stages such as quote, bind, renewal, and payment. Add in delegated authority, agents and business partners and this can be even more difficult.

Multiple Options

Our solution provides sophisticated screening that can be used throughout the policy lifecycle and cover all parties involved.

Tailor the screening to meet the needs of your firm. Added flexibility is available to enable a difference approach for different business lines.

Extend access to companies acting on you behalf to retain full control of your customer screening.

The Solution

Bring your customer screening up to date by loading all policy holders for screening. From this point we can monitor the policy holders and provide you with an alert should they match to a new entry on a watchlist. Once a policy is terminated the holders can be removed to ensure there are no further alerts.

Our transactional screening can cover the need for one-off checks against claimants. This will ensure you are protected from issuing payments to restricted parties.

Our screening service

How can we help your business?

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Frequently Asker Questions

Are insurance providers regulated by any supervisory bodies?

In the UK the Financial Conduct Authority (FCA) and the The Prudential Regulatory Authority (PRA) are the primary regulators for insurance companies, and require all authorised firms to adhere to the Proceeds of Crime Act of 2002, however insurers and brokers are not directly subject to AML rules and Money Laundering regulations.

Insurers and brokers are still required to set up systems and controls to reduce the risk of breaking anti money laundering laws. You may find anti money laundering guidance through one of the following insurance regulatory bodies associations:

  • The Prudential Regulatory Authority
  • International Association of Insurance Supervisors
  • Association of British Insurers
  • British Insurance Brokers’ Association
  • International Underwriting Association
  • Global Federation of Insurance Associations

Further details are available on the ABI website here.

What is sanctions screening and why does it matter in insurance?

Sanctions screening checks people and organisations against official lists of restricted parties so that you don’t place cover, pay claims, or provide services in breach of law. In insurance, exposure arises at quote, bind, endorsement, renewal and claims—including payments to third‑party beneficiaries and vendors. Breaches can lead to strict‑liability civil penalties, criminal exposure in some regimes, licence implications, and reputational damage.

Guidance is available for the OFSI and OFAC

Who must be screened in insurance workflows?

Underwriting & placement: policyholders (individuals & entities), UBOs and controllers (where in scope), beneficiaries, cover holders/MGAs, delegated claims handlers, and key vendors in higher‑risk lines (e.g., marine, aviation).

Claims: claimants, assignees, third‑party beneficiaries, payees and service providers (loss adjusters, lawyers, salvage, medical networks), before settlement or reimbursement.

This reflects where insurers and intermediaries may “make funds or economic resources available” to a sanctioned party.

What is the OFAC 50 Percent Rule and why does it matter?

Under US rules, an entity owned (directly/indirectly) 50% or more in the aggregate by one or more SDNs is itself blocked—even if not named. Screening must therefore look beyond names to ownership structures. Control alone (without ≥50% ownership) doesn’t automatically block—but it’s a red flag requiring enhanced diligence.

Find further guidance on the OFAC website here.

What level of Client Due Diligence (CDD) should be applied?

CDD should initially be performed at the start of a client/ business relationship and you may wish to apply it again at trigger events such as a claims payout or a change in customer circumstances.

The level of due diligence should correspond to the level of risk identified with the relationship as set out by your risk assessment.

  • Standard Client Due Diligence would be applied to the majority of cases, where no high risks have been identified.
  • Enhanced due diligence should be applied in high risk cases, and may include adverse media screening and source of funds/ wealth checks.
  • High risk factors include your customer and any beneficiaries, the product or service you are providing, the use of intermediaries and the location of customers or products
Which Insurance products would be considered high risk?
  • Single premium products
  • Anonymous insurance products, or products which can be easily transferred
  • Early surrender products, or high value surrender products
  • Products with cooling off periods
  • Large fund-specific products
  • High risk payment products
  • Top-up premium products
What does it mean to have a Risk Based Approach when performing AML as an insurance provider?

A risk based approach avoids adopting a one size fits all approach to anti money laundering operations, instead adapting customer due diligence and monitoring to scenarios dependent on the risk they pose.

You should have a risk assessment in place which will identify, evaluate and provide solutions for potential risks that your business may face.

Adopting a risk based approach would include applying various levels of due diligence, depending on risks identified or adjusting monitoring and rescreening policies.

What are red flags that may be an indicator of Money Laundering?
  • Early policy surrender/ withdrawal
  • Frequent beneficiary changes
  • Overpayment of premiums followed by refund requested
  • Third parties involvement in payment or payout
  • Large cash payments