Source: OJ L, 2024/1624, 19.6.2024

Current language: EN

Article 44 Politically exposed persons who are beneficiaries of insurance policies


Summary What does Article 44 of the Anti-money laundering regulation (AMLR) say?

This article addresses a specific scenario within the politically exposed persons (PEPs) framework established by Article 42: the point at which insurance policy beneficiaries come into focus.

Rather than applying PEP checks at the outset of a relationship, obliged entities are required to screen beneficiaries of life or investment-related insurance policies for PEP status at a later, specific trigger point — namely, at the time of payout or policy assignment.

If higher risks are identified at that stage, two additional measures kick in on top of the standard customer due diligence obligations already set out in Article 20.

Important points:

  • Check whether insurance policy beneficiaries (or their beneficial owners) are politically exposed persons, and do so no later than at the time of payout or policy assignment.
  • Where higher risks are identified, inform senior management before paying out policy proceeds.
  • Where higher risks are identified, conduct enhanced scrutiny of the entire business relationship with the policyholder.

Springlex's summary of the article, a reading aid, not a substitute for the legal text.

Obliged entities shall take reasonable measures to determine whether the beneficiaries of a life or other investment-related insurance policy or, where relevant, the beneficial owner of the beneficiary are politically exposed persons. Those measures shall be taken no later than at the time of the payout or at the time of the assignment, in whole or in part, of the policy. Where there are higher risks identified, in addition to applying the customer due diligence measures laid down in Article 20, obliged entities shall:

  1. inform senior management before payout of policy proceeds;

  2. conduct enhanced scrutiny of the entire business relationship with the policyholder.

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