FIAU Interpretative Note on Insurance Intermediaries Activities

On the 2 February 2021, the Financial Intelligence Analysis Unit (FIAU) issued an interpretative note aimed to those persons carrying on insurance intermediary activities. It has now been clarified that those insurance intermediaries who do not carry out any distribution activities related to life or long-term business are not considered as subject persons, and therefore not required to carry out anti-money laundering obligations.

In the case where an insurance intermediary decides to start distributing long-term insurance policies, such intermediary is required to register with the FIAU through the CASPAR system. In the case an insurance intermediary decides to cease distributing long-term insurance contracts, the intermediary would still be bound to carry out its anti-money laundering obligations if it is still serving and handling existing long-term insurance business (including for example collection of premium from clients in relation to long-term business). Where an intermediary ceases to provide long-term insurance business, the intermediary is still required to retain records for a period of 5 years.

The interpretative note also clarifies the obligations of Tied Insurance Intermediaries (TII). Where a TII is enrolled to carry out general business activities, the anti-money laundering regulations will not apply to the TII. TIIs are also exempt from carrying out their anti-money laundering obligations where the TII:

  1. Is a natural person and has been enrolled so that the TII can carry out activities on behalf of an entity that has itself been enrolled as TII; or
  2. The TII does not collect premiums, or other amounts intended for the policyholder or beneficiary.