United States: corporate life-insurance onboarding

First determine whether the insurer is issuing or underwriting a covered product under 31 CFR 1025: permanent life insurance other than group life, annuities other than group annuities, or other insurance with cash-value or investment features. Term and group products do not become covered solely because a company purchases them.

Obtain the purchaser and payment evidence

The insurer's risk-based AML programme determines the customer information needed. Obtain the corporate purchaser's formation records, authorised representative and premium-funding details. The US registry guide explains state records and where ownership information must come from the company.

Record the insured person, beneficiary, payer and any assignee. Request the corporate authority for the purchase and the assignment agreement where a lender receives policy rights. Investigate unexplained third-party premiums, rapid surrender and payments to unrelated recipients.

The bank CDD rule's universal 25% ownership certification is not an insurance requirement under Part 1025. Obtain ownership and control evidence where needed by the insurer's risk-based programme; do not label a bank certification form mandatory for every policyholder.

Agents, escalation and policy events

Part 1025 requires the insurer to integrate agents and brokers into its programme and obtain relevant customer information from them. The insurer remains responsible for its programme even when an intermediary collects documents.

Apply sanctions controls and investigate suspicious policy activity. Preserve the review and escalation evidence; where a SAR is filed, retain it and its supporting documentation for the required five years. Review assignments, surrenders and payout instructions under the programme before releasing funds.