Bermuda: corporate life-insurance onboarding

Apply the BMA framework to covered long-term insurance business; the insurance AML scope excludes reinsurance. Obtain the company's registration and constitutional records, business details and ownership evidence. Apply the required beneficial-owner and relevant chief-executive checks.

Authority and policy parties

Verify the representative and purchase authority. Record the insured person, payer and beneficiary, including assignments or lender rights. Obtain the assignment and funding agreement where those rights or payments are material to the proposal.

If an unrelated party pays premiums, obtain the explanation and supporting payment evidence. Review a proposed refund or surrender payment to a different account holder before processing it.

Beneficiary timing under paragraph 3.15

The BMA guidance requires policyholder identification and verification before establishing the relationship. Identify a beneficiary when designated. Verification may occur later, but must be complete at payment or when the beneficiary exercises a vested right or power of control.

For a corporate or trust recipient, obtain the relevant ownership or trust-party evidence required by the framework. Apply enhanced and PEP measures where required and resolve sanctions findings.

Review beneficiary amendments, assignments and surrender instructions against the current policy rights. Retain the evidence establishing the recipient and their entitlement with the payment approval.