Singapore: corporate life-insurance onboarding

MAS Notice 314 applies to direct life insurers for life policies; it excludes reinsurance. Obtain the corporate policyholder's registration records, business details and the identity and authority of its representative. The ACRA guide identifies the records available for Singapore companies.

Check the policyholder's owners

Identify the individuals who ultimately own or control the company and take reasonable measures to verify them. Use shareholder records for corporate ownership layers and control agreements where voting or appointment rights differ from the shareholdings. Document any applicable exemption rather than treating every listed group as automatically exempt.

The proposal should state who is insured, who pays the premiums and who receives the benefits. For a company buying cover on a director's life, obtain its explanation of the cover and the director's relationship to the business. Investigate premiums paid by an unrelated party.

Beneficiaries and other recipients

Record named beneficiaries, or sufficient details of a class of beneficiaries to identify the recipient when payment becomes due. Apply the notice's beneficiary-verification requirements at payout.

Paragraph 6.21 also requires verification of a payee other than the customer when paying surrender proceeds, premium refunds or other policy monies. Obtain the assignment or payment authority where the recipient has changed; the original beneficiary nomination may no longer explain the payment.

Keep policyholder CDD current during the relationship. Escalate unusual premium payments, assignments and early surrender under the insurer's risk and suspicious-transaction procedures.