Luxembourg: corporate life-insurance onboarding

Luxembourg life and investment-related insurance business is covered by the AML law of 12 November 2004. The insurance supervisor is the Commissariat aux Assurances. Obtain the corporate policyholder's registration, constitution and business details; the RCS guide explains local company extracts and filings.

Company owners and the applicant

Identify beneficial owners and take reasonable measures to verify them. Obtain shareholder records for relevant corporate layers and agreements conferring control. Apply the law's ownership and control tests; use senior management as a fallback only on the statutory conditions.

Verify the representative's identity and authority to buy the policy. Obtain the company mandate and identify who may assign, surrender or amend it. Record the insured person, payer and reason for the cover.

Beneficiary designation and payout

Record a named beneficiary when designated, or sufficient information about a class or description to establish the recipient at payout. Complete beneficiary verification at payout and apply the additional measures required for higher-risk beneficiaries and relevant PEPs.

For a corporate recipient, obtain its registration and ownership evidence where the applicable checks require it. Request the assignment agreement if a lender or another party has acquired policy rights; review payment instructions against the current entitlement.

Monitor premium payments and policy changes, including third-party funding and early surrender. Keep the CDD evidence, nominations, assignments and approval records under the AML law's retention provisions.