Insurance AML Advisory
Insurance AML questions are shaped by policy design, customer journeys and the way value moves through premiums, benefits and claims. Advice should reflect the insurer's products, risk exposure and applicable jurisdiction.
Insurance Transaction Monitoring
Review insurance AML monitoring across policy, premium, refund, claim and beneficiary activity in the context of unusual behaviour.
Read moreConsider insurance products on their own terms
Start by mapping the insurer's products and processes; a banking control template may not transfer unchanged. For life and investment-linked products, discussion may cover premium patterns, beneficiary changes, policy value, withdrawal or early surrender, and review points. Indicators depend on policy terms, customer context and other evidence; an event alone does not establish suspicion.
Non-life products have different payment and claims journeys. An advisory review can examine premium overpayments or refunds, payment sources, policy changes and claim-related financial crime risks within the wider control picture. Exposure and obligations vary by product and jurisdiction.
Connect policy, data and monitoring
Does the risk assessment reflect products, distribution, customer and beneficiary profiles, jurisdictions, payment paths and operating model? Discussion may then consider related policies, due diligence, screening, monitoring, escalation and management information. Trevor Barritt's November 2023 insurance paper discusses indicators such as early surrender and beneficiary changes, and argues banking-derived patterns may not fit insurance activity. It is a dated perspective, not current law or a claim about an insurer's controls.
FATF's non-binding 2018 life insurance guidance says assessment should reflect business nature, size and complexity; it also notes that later FATF standard revisions are not reflected. In the UK, applicable rules depend on insurer, intermediary, product and activity; FCA Handbook SYSC 6.3 applies to firms within its scope. Cross-border groups need to establish local requirements rather than assume one country's perimeter applies everywhere.
Scope a practical advisory question
An initial discussion identifies the entities, jurisdictions, products or processes, decision question, existing risk assessment and policies, available evidence and constraints. Advisory work can then examine a defined issue or how operating-model elements address risk. Findings reflect the evidence reviewed and the agreed question.
Insurance products and customer and payment journeys provide the starting context. Applicable laws and supervisory expectations depend on the product, entity and jurisdiction.
Common questions
Does this cover life and non-life insurance?
Both may be discussed, but their products, activity and legal treatment can differ. The relevant line of business, jurisdiction and question must be agreed before scope is proposed.
Does insurance AML advisory include claims fraud investigation?
No. Claim-related activity can form part of an AML risk or control review, while claims-fraud investigation remains a separate activity.
Can a banking transaction monitoring template be used for insurance?
It should not be assumed to fit. Product design, policy events, customer behaviour and data can differ, so the suitability of scenarios and controls should be considered against the insurer's own risks and evidence.