FC-4.1 FC-4.1 Internal Reporting
FC-4.1.1
Insurance licensees must implement procedures to ensure that staff who handlecustomer business (or are managerially responsible for such staff) make a report promptly to the MLRO if they know or suspect that acustomer (or a person on whose behalf acustomer may be acting) is engaged in money laundering or terrorism financing, or if the transaction orcustomer's conduct otherwise appears unusual or suspicious. These procedures must include arrangements for disciplining any member of staff who fails, without reasonable excuse, to make such a report.Amended: January 2007FC-4.1.2
Suspicious transaction or conduct may include a claim made in suspicious circumstances, a policy surrendered soon after inception or in circumstances that would otherwise appear contrary to the interests of a reasonable
policyholder . If a prospectivepolicyholder does not pursue an application, this may be considered suspicious in itself. Item FC (iv) in Part B of Volume 3 (Insurance) provides further examples of transactions that may be suspicious or unusual.Amended: January 2007FC-4.1.3
Where
insurance licensees' internal processes provide for staff to consult with their line managers before sending a report to the MLRO, such processes must not be used to prevent reports reaching the MLRO, where staff have stated that they have knowledge or suspicion that a transaction may involve money laundering or terrorist financing.
