ADGM: corporate life-insurance onboarding
Corporate life-policy checks for FSRA-authorised insurers in ADGM under local AML rules and federal beneficiary provisions.
ADGM · Life insurers · FSRA
Corporate policyholders · Life insurance: AML/CDD review
By Matthew Lee
Logo: UAE government portal
Confirm the insurer's permission for the proposed life business. Obtain the policyholder's registration, governing documents, addresses and business details under AML 8.3.2. Use the customer's registration authority for UAE company evidence and home-country records for an overseas entity.
Owners and policy instructions
AML 8.3.3 includes individuals owning or controlling 25% or more of shares or voting rights and those exercising the specified other control. Obtain the relevant ownership records, verify beneficial owners as required and document any exception or fallback used.
Verify the representative and authority for the purchase. Obtain the mandate covering assignments, surrender and changes to payment rights, with the financing agreement where a lender will receive benefits.
Premiums and recipients
Record the insured person, payer, beneficiary and purpose of the cover. Request evidence for premiums paid by a different company or person.
Apply the federal provisions for beneficiary details at designation and verification at payout or exercise of relevant rights. Higher-risk corporate beneficiaries require additional beneficial-owner checks; relevant PEP cases require the specified enhanced measures.
ADGM AML 8.4 requires enhanced enquiries, source-of-funds and source-of-wealth checks and senior-management approval for higher-risk relationships. Review changed policy rights and recipient instructions under ongoing CDD before payment.