Unusual Transactions or Customer Behaviour
FC-2.2.5
In instances where an
insurance licensee’s risk-based monitoring systems identify significant or abnormal transactions (as defined in FC-2.2.2 and FC-2.2.3), it must verify the source of funds for those transactions, particularly where the transactions are above the transactions threshold of BD 6,000. Furthermore,insurance licensees must examine the background and purpose to those transactions and document their findings.Amended: January 2022FC-2.2.6
The investigations required under FC-2.2.5 must be carried out by the MLRO (or relevant delegated official). The documents relating to these findings must be maintained for five years from the date when the transaction was completed (see also FC-6.1.1(b)).
Amended: October 2007
Amended: April 2008FC-2.2.7
Insurance licensees must consider instances where there is a significant, unexpected or unexplained change in the behaviour ofpolicyholders' account (e.g., early surrenders).Insurance licensees must be extra vigilant to the particular risks involved in the buying and selling of second hand endowment policies, as well as the use of single premium unit-linked policies.Insurance licensees must check any reinsurance or retrocession to ensure that monies are paid to bona fide reinsurance entities at rates commensurate with the risks underwritten.Amended: January 2007FC-2.2.8
When an existing
customer cancels a policy and applies for another, theinsurance licensee must review its customer identity information and update its records accordingly. Where the information available falls short of the requirements contained in Chapter FC-1, the missing or out of date information must be obtained and re-verified with thecustomer .Amended: January 2007FC-2.2.9
Once identification procedures have been satisfactorily completed and, as long as records concerning the
customer are maintained in line with Chapters FC-1 and FC-6, no further evidence of identity is needed when transactions are subsequently undertaken within the expected level and type of activity for thatcustomer , provided reasonably regular contact has been maintained between the parties and no doubts have arisen as to thecustomer's identity.Amended: January 2007