Australia: corporate life-insurance onboarding

Identify the designated service being provided: issuing a policy, a relevant transfer or another covered action can trigger different steps. Apply the current initial-CDD requirements to the corporate customer. Obtain ASIC company records, ownership information and the identity and authority of the person arranging the policy.

Determine which people need checks

Establish the company's beneficial owners from its ownership and control structure. Record the evidence for any deeming provision used for a listed company, government body or other qualifying customer. For an unlisted corporate shareholder, obtain its ownership records rather than stopping at its company name.

Record the insured person, premium payer and beneficiary separately. The Rules include specific provisions for beneficiaries of life and sinking-fund policies; use those provisions for beneficiary timing rather than treating the beneficiary as the company purchasing the policy.

Before accepting premiums or paying benefits

Obtain the company's reason for the cover and its premium-funding arrangements. Request the loan or assignment documents where policy rights secure borrowing, and investigate unexplained third-party premiums or instructions to pay a new recipient.

Establish the relevant parties' PEP and sanctions status and apply enhanced CDD when required. Verify a representative's authority for assignments, surrender requests and other material instructions; the original purchase mandate may not cover them.

Keep CDD current through ownership changes and policy events. Retain the proposal, verification results, beneficiary nominations, amendments and payment evidence with the relevant decisions.