Tin Protekshon ora reportá? Is there protection when report?

The importance Compliance Requirements The results Conclusions Recommendations

Life Insurance & Intermediaries Compliance Survey

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April 20, 2023

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.

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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.

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More Companies have implemented a policy compared to Intermediaries

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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

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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.

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• 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.

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Companies opinion does diver w.r.t. Customer Due DiligenceCompanies opinion does diver w.r.t. Customer Due Diligence

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April 20, 2023

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.

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Transactions reported Frequency Percentage

0 14 53.8

1 1 3.8

2 1 3.8

3 1 3.8

4 0 0

5 1 3.8

Don’t know 7 26.9

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April 20, 2023

Most companies never reported any unusual transaction

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April 20, 2023

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.

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Insurance companies Insurance brokers

Record keeping

system

- Yes (100%)

- Yes (95%)

- No (5%)

Copies kept of - Internal generated reports

AML (50%)

- All CDD transactions and

ID’s customers (33%)

- Reports for external

purposes (17%)

- Internal generated reports

AML (35%)

- All CDD transactions and

ID’s customers (60%)

Timing to retain

copies

- 5 yrs. of longer (100%) - 5 yrs. of longer (85%)

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Record Keeping System well applied by both parties

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Insurance Companies and Intermediaries

Insurance Industry and Central bank

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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.

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April 20, 2023

Established a consistent approach of customer identification

Reporting of suspicious/unusual transactions

More training for insurance companies and intermediaries

Further research

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Life Insurance & Intermediaries Compliance Survey April 20, 2023