AML for insurers and intermediaries

Life insurance and investment-linked products, in every major regime, along with the brokers and intermediaries who distribute them. General insurance usually falls outside, and that exclusion belongs in your documented risk assessment so a supervisor can see it was decided, not assumed.

The policyholder, the payer and the beneficiary, brought together in one file at underwriting. In life insurance these are often three different people, and the risk usually sits with the one who is not the applicant, such as a third-party premium payer or a beneficiary named later.

Yes. The payer is a party on the same file from underwriting, and a change in who pays the premium triggers a rescreen. A third-party payer with no clear link to the policyholder is one of the classic red flags in life insurance, so it is checked, not assumed.

Yes. Brokers and intermediaries get their own file and are monitored like customers, including PEP and adverse media. An intermediary's risk can change after appointment, and a broker who brings in unusual business is often the first sign of a pattern across several policies.

Beneficiary change, assignment, a change in who pays the premium, and surrender, each configurable per product line. These are the points where control of the money shifts, so each one updates the same file the final payout is checked against. The underwriting score is never the last word.

The payout decision reads the whole file: underwriting, broker checks and every lifecycle event up to that point. A claim is checked against the risk score set when the policy was written, not against a new estimate based only on the payout request.

Yes. A payout can be held pending review, and the hold is recorded with a documented reason and an owner. The same record shows when the hold was released and on what evidence, which is what an examiner reads when they ask why a payment was delayed or allowed.

Only as an event feed. Assignments, beneficiary changes and surrenders arrive as events, and nothing about the policy record has to move or be rebuilt. Your policy administration system stays the system of record for the contract, and complead holds the AML file.

Laundering through life insurance usually happens on the way out: a large single premium paid in, then an early surrender or a cancellation in the cooling-off period that returns clean funds. The money shows up at surrender, not at the sale, so the check has to read the full policy history, including who paid in and who is now being paid.

Beneficiaries must be identified as soon as they are named or designated, and verified before payout, per policy. Where a beneficiary is described by class, such as "my children", identification follows once they can be determined. Keeping every beneficiary in scope on the same file is how that requirement is met.