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Complinet 3rd Compliance & AML Seminar KSA Money Laundering and the Insurance Industry: Trends, Risks, Indicators 23rd March 2011 Lisa Kelaart-Courtney Head Compliance Advisory Services Insurance Sector Vulnerabilities Clyde & Co LLP © 2011 Insurance sector risks LOW RISK DOES NOT EQUAL NO RISK Clyde & Co LLP © 2011 Regulatory Focus There are severe economic and social consequences of Money Laundering. • Undermining Financial Systems: Money Laundering expands the black economy, undermines the financial system and raises questions of credibility and transparency • Expanding Crime: Money Laundering encourages crime because it enables criminals to effectively use and deploy their illegal funds • ‘Criminalising' Society: criminals can increase profits by reinvesting the illegal funds in businesses • Reducing Revenue and Control: Money Laundering diminishes Government revenue and weakens Government control over the economy Clyde & Co LLP © 2011 3 Benchmarks International Standards Organisation for Economic Cooperation Development (OECD) Financial Action Task Force (FATF) International Association of Insurance Supervisors (IAIS) International Basel Organisation of Securities Commissions Committee for Banking Supervision Local Standards • • • • • Decrees Laws Executive Regulations Rules Guidance 4 Clyde & Co LLP © 2011 Defining Customer Due Diligence The concept of customer due diligence goes beyond the identification and verification of only the policyholder – it extends to identification of the potential risks of the whole business relationship. Life cycle – Continuous Vigilance Before entering the contract Testing, audit, improvement Testing, audit, improvement Pre contractual & ongoing business relationship Ongoing Due Diligence Trigger Events Testing, audit, improvement 6 Clyde & Co LLP © 2011