Japan: corporate life-insurance onboarding

Obtain the company policyholder's registration certificate, business details and authorised representative's information. For Japanese entities, the commercial register records company particulars and registered representatives; obtain the shareholder register from the company for ownership checks.

Establish who can instruct the insurer

Verify the person arranging the policy and their authority. Request a delegation where the applicant is not the registered representative, and record who may submit assignments, surrender requests and changes to payment instructions.

Identify beneficial owners from shareholder and control records. For an overseas holding company, obtain its home-registry records and ownership evidence for the relevant intermediate entities.

Review the cover and funding

Record the insured person, beneficiary, premium payer and the company's reason for the cover. A key-person proposal should identify the employee or director covered; a financing arrangement should identify any lender receiving assigned policy rights. Request the assignment agreement when it affects who can claim or surrender the policy.

The FSA's March 2026 Guidelines require risk assessment, ongoing monitoring and enhanced measures for higher-risk relationships. Obtain funding evidence where a large premium, third-party payment or proposed early surrender needs explanation. Escalate material sanctions, PEP and adverse-information findings under the insurer's procedures.

Keep beneficiary nominations, assignments and verification results with the policy record. Reassess the affected parties when ownership or payment rights change, and complete the checks required for the recipient before releasing policy money.