The IAIS should make it clear in its final application paper that non-life insurance falls outside of the scope of the FATF recommendations
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the suggested approach to document validation is outdated in a digital world, even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.
Insurance Europe
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