Assurance Non Vie – The anti-money laundering and countering the financing of terrorism (AML-CFT) regulatory environment is constantly evolving. At the same time, regulatory requirements are higher. AML-FT measures, asset freezes and international sanctions are mandatory in France for life insurance as well as non-life insurance (which covers non-life insurance – such as car, home, liability and personal or health insurance, preventive insurance).
, the Sanctions Committee of the Prudential Regulation and Resolution Authority (ACPR) marked a turning point at the end of 2021. In fact, it was the first sanction against a “non-life” insurer for deficiencies in the asset freeze system.
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From that point on, the French supervisor’s attention to the measures implemented in the field of AML-CFT among “non-life” actors increased continuously. There are a number of audits underway that will go to general insurers and mutuals. Note that unlike AML obligations, which are asset obligations, a system for tracking designated persons or entities is performance-based. In any case, the latter should allow the application of freezing measures and the prohibition of all operations that fall within the scope of those measures.
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Our position is about the use of sanctions lists and screening tools to detect the possible presence of persons involved in terrorism. But remember that the ACPR also calls on regulated entities to be vigilant in detecting “weak signals” of terrorist financing.
At all stages of the lifetime of the contract, i.e. at the time of subscription and during the entire duration of the contract (whether it is collection or disbursement). Fulfilling these obligations is not easy, especially because:
→ Many third parties may be included in the contract, especially in the case of payments to uninsured/subscribing beneficiaries and even deferred payments. These third parties constitute additional groups that the asset freeze must examine when paying out after the relationship is established (for example, company employees and beneficiaries of collective health or welfare agreements, mechanics or experts involved in disasters, etc.) or even after the contract has expired. also (for example, a temporary or life annuity due to the surviving spouse for foresight or a ten-year guarantee in connection with the civil liability of builders).
→ KYC data on customers and third parties is usually quite weak and rarely up-to-date. In order to comply with the new AML-FT obligations, the opt-in and KYC data update processes were only partially reviewed. Often, there are also missing documents that allow verification of identification data.
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It should be remembered that, contrary to what is sometimes heard, nominees or entities are relatively more common in non-life insurance contracts than in life insurance. This can be explained by the fact that the word “financing” can be misleading: in fact, the regulation prohibits not only the provision of funds, but also economic instruments such as driving or allowing accommodation. .
2. What are the most frequently observed weaknesses of non-life insurers’ asset freezing systems?
In order to meet regulatory requirements and calmly respond to or anticipate a likely ACPR audit, the insurance organization must take full ownership of the subject and take the necessary steps to identify the strengths and weaknesses of its system.
First, let’s recall the main stages of tracking and reporting designated individuals using the diagram below:
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All of these steps are important because failure to freeze assets is “particularly serious given the primary interest in protecting public order and public safety to which asset freezing legislation responds. tools in connection with the fight against money laundering and terrorist financing”
When collecting information, the main focus is on the district to be filtered with mandatory identification data. Sometimes observed:
The identification data integrates the filtering device according to specific frequencies and specific time periods. Sometimes observed:
Sometimes there are problems with the official lists of asset freezes and applied international sanctions and their updates:
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The configuration of the name filter is a critical point of the system. For effective filtering, the device and/or its setting method:
There’s no point in being quick to detect if the alarms aren’t being responded to quickly either. In fact, it can sometimes be observed:
The results of the screening must be incorporated into the subscription and management tools to be taken into account by the business units, for the immediate implementation of freezing and lifting measures. There are also important questions here, also on a business level. In fact, it is often observed:
Finally, attention is often drawn to the insufficient constant control of the system and the quality of the documentation, for example:
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Updating the system to track and process designated individuals is mandatory. Failures are increasingly punished. Those issues, including those affecting civil society, are of key importance, and they pay more and more attention to the behavior of financial actors. Many interventions for our clients allow us to share feedback to address previously identified gaps. Listed below are “quick wins” and recommendations for adaptation and/or addition to your context and specifics (proposed contracts, organizational and distribution networks, etc.).
The completeness and quality of the personal data is a prerequisite. Therefore, these must be defined and strictly controlled by the insurance organization.
Indeed, engagement processes (for each customer journey) and management need to be rethought to collect the identifying data needed for relevant screening. They should also encourage verification of this data by collecting supporting documents. Note that data collection and updating can be shared between the second and first lines and can be partially automated.
“A priori” or “a posteriori” filtering is relative and may reflect the need for so-called “real-time” filtering (as opposed to batch filtering according to a specified frequency), especially before payment operations. fulfilled. .
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When it comes to a relationship, it’s important to plan your screening at the right time and as soon as possible for your prospects. The key here is to connect filtering/filtering solution tools with CRM (Customer Relationship Management) applications.
As a result, the development of subscription/management tools should be expected, with particular attention to blocking methods and the information available in case of tracking down persons or entities subject to sanctions.
If most insurance organizations equip themselves with filtering tools that enable finding names with a specific match ratio (“fuzzy match”), then the algorithms defined simply based on “distances” will no longer respond effectively to their needs (e.g. foreign language so-called “phonetic” filtering names).
Publishers of some filter solutions offer modules that enable the reduction of “false positives” by combining detection through algorithms with rules or even new technologies (e.g. Machine Learning, Entity Resolution).
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To determine whether the filter settings are working properly or require optimization, two test methods can be implemented:
• Benchmark elements of market practices that allow you to compare your settings (threshold selection or detection rules) to other users of similar solutions.
• “Crash test” of the device by filtering different customized test cases according to the organization’s needs and specific cases (e.g. definition of names in certain languages or a list of certain countries)
The processing of alarms can be handled by the insurance organization itself, centralized in the case of a group, or subcontracted (for example, in Shared Service Centers). In the latter case, the organization must check the processing times and the quality of the analyzes performed. To this end, you must implement, in particular, permanent and periodic control measures.
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Depending on the situation, it is also possible to “preliminarily analyze” the alarms in order to implement technological solutions:
• RPA (Robotic Process Automation) to collect and supplement portfolio person information if not directly available in the screening tool
Odilon is responsible for Deloitte Risk Advisory’s compliance, internal audit and operational risk activities
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