Artikel 44 Personer i politiskt utsatt ställning som är förmånstagare i försäkringsavtal

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.