Bahrain: corporate life-insurance onboarding
Corporate policyholders, 20% shareholders and payment recipients under Bahrain's CBB insurance Financial Crime module.
Bahrain · Life insurers · Central Bank of Bahrain
Corporate policyholders · Life insurance: AML/CDD review
By Matthew Lee
Registry: Sijilat commercial registration system
CBB Volume 3, module FC, requires CDD for new insurance relationships and relevant changes. Obtain registration and governing documents, addresses and business details for the company buying the policy. The Sijilat guide identifies available local records.
Ownership and representation
The corporate provisions include identification and verification of shareholders holding 20% or more of issued capital where applicable, alongside ultimate-ownership, funding and control enquiries. Obtain the relevant evidence for corporate shareholders and other controllers.
Verify the representative and purchase authority. Record the insured person, payer and beneficiaries. FC-1.1.8 requires beneficiary checks and establishment of the relationship between insured and beneficiaries.
Payment and verification timing
FC-1.1.9 requires verification of a recipient other than the policyholder for claims, commissions and other monies. Obtain the assignment or payment authority where a lender or another party is entitled to the funds.
FC-1.1.12 addresses timing, including specified cases where funds may be received before verification is complete. In those cases no disbursement may occur before the relevant CDD is fully met. Do not defer every check to a claim-stage workflow.
Review changes to signatories, beneficiaries and material policy terms under the FC triggers, applying enhanced measures and approvals where required.