AML/CFTR 4.3.11 CDD for PEPs as beneficiaries of life insurance policies

(1) Before making a payout from a life insurance policy, a financial institution must take reasonable measures to determine whether the beneficiary, or the beneficial owner of the beneficiary, of the policy is a PEP.
(2) If the beneficiary or its beneficial owner is a PEP and the PEP presents a higher risk, the firm:
(a) must inform its senior management;
(b) must conduct enhanced CDD of its business relationship with the policyholder; and
(c) must make a suspicious transaction report to the FIU.
Derived by QFCRA RM/2019-8 (as from 1st February 2020)