Recent and upcoming regulatory changes, and particularly changes to the Policyholder Protection Rules and the Financial Intelligence Centre Amendment Act, are shifting the industry to a risk based (rather than a rules based) approach to compliance and to how we conduct business in general.

One area impacted by these changes is the due diligence process at on-boarding and on an ongoing basis, and we will now all be required to know more about the clients we do business with.

Customer Due Diligence is the process of identifying your customers and verifying who they say they are. In practice this means obtaining specific documentation and information pertaining to the group schemes/employers and their beneficial owners. This includes, but is not limited to, company documents, proof of business address, company organograms and the identification of shareholders and authorised persons. Insurers will be asking for this information on new and existing clients with immediate effect and may, at times, contact clients directly to acquire the necessary information.

We are currently working with our insurers to agree on one standard and consistent format across all of them and should this be successful, we will make the forms and templates available to you. These may simplify you meeting your regulatory requirements and you are welcome to make these part of your Risk Management and Compliance Programme should you wish.

We hope to assist with these new regulatory requirements wherever we can and please feel free to get hold of the office or your TSA Associate if you have any questions pertaining to the changes and the resultant requirements on us all.

(Vol 8 Issue 17)