Germany: corporate life-insurance onboarding

GwG section 2(1)(7) defines the covered insurance activities. For a corporate life-policy customer, obtain its registered particulars, representatives and ownership information. A Handelsregister extract records company and representation details; a GmbH's Gesellschafterliste supplies filed shareholders.

Policyholder and representatives

Identify beneficial owners under GwG section 3: more than 25% of capital or voting rights, or comparable control, subject to the statutory provisions. Obtain the relevant records for indirect owners and control arrangements, and the required beneficial-ownership register evidence.

Verify the representative arranging the cover and their authority. The extract may require joint representation; a single signature from one director may therefore need an additional signature or valid delegation.

Insurance parties and payment instructions

Record the insured person, premium payer, beneficiary and any assignee. Obtain the company's reason for the cover and documents supporting a third-party premium or an assignment securing borrowing.

Apply the insurance-specific beneficiary checks, alongside the general GwG duties. Record beneficiary details at designation and complete the required verification at payout. Apply the relevant PEP and enhanced measures before payment where required.

Review changes to beneficiaries, ownership and surrender instructions during the policy. Verify that the person issuing a new instruction still has authority and that the recipient is entitled to the funds. Keep the CDD evidence and policy amendments with the risk and payment decisions.