South Africa: corporate life-insurance onboarding

FIC Act Schedule 1 item 8 covers the relevant life-insurance business and excludes reinsurance. Obtain the corporate policyholder's CIPC or home-registry records, governing documents, business details and ownership structure.

Owners and representatives

Apply section 21B's sequence of controlling ownership, other control and senior-management fallback. Identify beneficial owners and take reasonable measures to verify them. The Act does not supply a universal 25% ownership rule for this process; retain the evidence and the basis for the insurer's risk assessment.

Verify the representative and authority to purchase the policy. Obtain the company mandate for later assignments, surrender and changed instructions.

Purpose, premiums and recipients

Establish the reason for cover and expected funding under section 21A. Record the insured person, payer and beneficiary. Obtain evidence explaining third-party premiums and the financing or assignment documents where a lender receives benefits.

Apply the insurer's beneficiary and payment controls under its Risk Management and Compliance Programme. Before payment, establish the recipient's entitlement, relevant identity evidence and authority for the instruction. Review early surrender and payments to a new recipient against the current policy rights.

Apply enhanced and prominent-person measures where required and resolve sanctions findings. If required CDD cannot be performed, apply section 21E and consider section 29 reporting; retain the supporting review and decision.