Insurance Europe has published its response to a consultation by the International Association of Insurance Supervisors (IAIS) on its draft revised application paper on combating money laundering and terrorist financing (ML/TF).
The IAIS aims to ensure consistency with the recommendations of the Financial Action Task Force (FATF) and the latest version of ICP 22, which covers anti-money laundering and combating the financing of terrorism.
The IAIS should make it clear in its final application paper that non-life insurance falls outside of the scope of the FATF recommendations and that, in this area, the risk of ML/TF is close to non-existent outside of fraud. Therefore, non-life case studies do not really belong there.
The industry is concerned about the IAIS’s proposed information requirements to identify a customer, as they go beyond what is required at EU level and without, in some cases, any added value. Furthermore, the suggested approach to document validation is outdated in a digital world, even given the differences between countries in terms of levels of digitisation.