AML Presentation & KYC Ver 1.9

Anti Money
Laundering
and
Know Your
Customer
11/15/15
Sales Training -AML Presentation Ver 1.9
Agenda
Anti Money Laundering Regulations
Moral Hazard Report (MHR)
Process of Money Laundering
Enhanced Due Diligence
Obligation of SUD Life
Suspicious Transactions
Procedure for identification of

Beneficial Ownership
Exceptions to AML
Know Your Customer (KYC)
What is FATF?
Impact of Anti Money Laundering
KYC Requirements
Risk Assessment
Summary
11/15/15
What
Money
Laundering
Money is
Laundering
is defined
as movement?of
illegally acquired cash through financial
systems so that it appears to be legally
acquired.
11/15/15
Money Laundering is the processing of DIRTY

MONEY, in order to disguise their illegal origin.
Dirty Money are proceeds derived from criminal

conduct.
Criminals want the money to look like it came

from a legitimate source.
Anti Money Laundering Regulations

In India, Anti Money Laundering (AML)
measures are controlled through The
Prevention of Money Laundering Act,
2002, which was brought in force with
effect from 1st July 2005.
IRDA
has
made
the
AML
guidelines
mandatory for all insurance companies

with effect from 1st August 2006.
FIU-IND (Financial Intelligence Unit) is a
govt. set up responsible for receiving,
processing, analyzing and disseminating
information relating to suspicious financial/
cash transactions.
Compliance to these AML norms is required
11/15/15
Process of Money Laundering
11/15/15
Process of Money Laundering (Continued...)

Placement:
Placement: This is the first stage where criminals dispose off physical
cash proceeds derived from illegal activities.
Some methods used here are: small but regular deposits or
investments.
For example: a customer taking multiple insurance policies for cash
premium under Rs. 50,000.
11/15/15

Layering:
Layering: This stage concentrates on separation of proceeds from

criminal activity through the use of various layers of monetary
transactions.
These layers are aimed at clearing away the audit trails, disguise the
origin and maintain anonymity for people behind the transactions.
For example:
frequent free-look cancellation, frequent top up
premiums, using multiple bank accounts, intermediaries and7 countries
11/15/15

Integration:
Integration: At this stage, the laundered proceeds are placed

back into the economy in such a way, that they re-enter the
financial system appearing to be normal business funds
(legitimate funds).
For example: investment products, fixed assets, etc.
11/15/15

Lets Recap.
Placement
g
rin
ye
La
Integration
11/15/15
Obligation of SUD Life

As directed by the regulator, u/s 12 of the PMLA, SUD Life
has an obligation to verify identity of its clients and beneficial
owner, report transaction and maintain records.
This covers:
Maintenance of records of all transactions.
Maintenance in such a way that reconstruction of individual transactions is possible at a
later date.
Reporting of attempted transactions.
The obligation of verifying and identifying the clients, including the beneficial owners.
Time limit for maintenance of records for reportable transactions and identity of clients
and beneficial owners. The obligation for maintenance of records of identity is linked to
Note:
Beneficial
Owner
as perof accounts.
PLMA is the natural person on whose
end of business
relationship
or closure
behalf the transaction is being conducted and includes a person who
exercises ultimate effective control over juridical person.
Process for identifying beneficial owner is covered in subsequent slides.
11/15/15
10
AML/ KYC Requirements

AML/ KYC guidelines apply for all proposals logged
in from 1st August 2006, including cases where
customer has previous policies with us.
AML/ KYC will be applicable at the following
stages :
2)
1) New
3)
Policy
Business
Claims
Servicing
11/15/15
11

AML/ KYC Grid (Based annualized premium)
Where annualized premium is equal to or more than Rs. 50,000, it is

mandatory to submit PAN OR
Declaration for PAN exemption in specified format for NRIs / Agriculturists
(via Form 60 / 61).
If premium payer is different from Life to be Assured (e.g. Husband paying for
Wife), KYC of the Life to be Assured and the income details of Premium Payer
need to be furnished.
Proposers AML / KYC documents are required where the life to be assured is a
minor or housewife or premium remitter is other than life assured.
11/15/15
12

New Business
In case of new contracts, KYC should be done before the issue of
every contract. While carrying out the KYC exercise special care to be
taken to ensure that contract is not under anonymous or under fictitious
names.
SUD Life will not enter into a contract with a customer whose
identity matches with any person with known criminal background or with
banned entities and those reported to have links with terrorists
or terrorist organization.
Acceptance of cash (inclusive of renewal premium & top up premium) is
not permitted under Bancassurance Channel. It would be acceptable only
through cheque / demand draft / any other banking instrument.
Remittances of premium by cash above Rs. 50,000/- will be accepted under
Agency Channel only on per transaction basis subject to customer quoting
of PAN.
SUD Life shall verify the authenticity of the details of PAN so obtained. In
case of customer not required to have PAN or with an agricultural income,
13
11/15/15
13
Form 60 / 61 prescribedSales
under
Income
Tax ActVer
will
Training
-AML Presentation
1.9 be obtained.
AML/KYC Requirements
Policy Servicing
Top Up Premium (Amount which is paid
over and above the premium):
If
Top
up
Annualized
regular
premium
(combined
or
separately) is equal to or more than Rs.1 lac, proof of income is

to be submitted.
KYC is to be carried out at times when the top up remittance is

inconsistent with the customers profile.
Any change in the customers recorded profile that comes to

the notice of sales staff/ back office staff, which is inconsistent
with the
normal and expected activity of
the
require KYC exercise to be taken afresh.

11/15/15
14
customer will

Policy Servicing
Assignment
(An assignment transfers the rights, title and
interest of the assignor to the assignee)

At the time of assignment, the requirements are:
Relationship with assignee
Identity proof of assignee
Address proof of assignee
If assignments are made to parties (other than parents /
spouse / children / member of a Hindu Undivided Family) or to

entities other than financial institutions; in addition to the
above, proof of insurable interest will be required.
11/15/15
15

Policy Servicing
Address Change:
All residential address change requests to be submitted with proof of new

address.
Redemption / Surrender:
No payments will be allowed to 3rd parties except in cases like
superannuation / gratuity accumulations and payments to legal heirs in
case of death benefits
Clients / agents indulging in free look cancellations (i.e. cancellation of
policy within the permitted time frame as defined in the policy document)
on multiple occasions will be monitored closely.
11/15/15
16
16

Claims
KYC is to be carried out at the time of claim payout stage.
Along with the claim form:
Residence proof of the nominee is to be submitted.
Identity proof of the nominee is to be submitted.
All Payments exceeding Rs.10,000/- per claims should be
made through account payee cheque, electronic payment
methods such as ECS, NEFT systems approved by RBI.
11/15/15
17
Know Your Customer

Due Diligence:
Considering the potential threat of usage of
financial services, SUD Life will make reasonable
efforts to determine the true identity of all of its
customers. It will also ensure that insurable
interest is established in all cases where premium
is paid by persons other than the person insured.
In order to establish the identity of its customers,
an effective procedure is put in place.
Know Your Customer

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18
Enhanced Due Diligence

Source Of Fund
11/15/15
Details of sources of funds for all policies to be obtained,

where the annual premium per policy is equal to or
greater than Rs. 1 lac, in a financial year.
Mere documentation of income proof does not
constitute establishing source of funds.
Enhanced due diligence has to be carried out while
ascertaining sources of funds.
Sources of fund should be obtained through
questionnaire / declarations on sources of fund / details
of bank accounts etc.
19
Enhanced Due Diligence Measures

Some reasonable measures in carrying out detailed due diligence:
More frequent reviews of the customers activities / profile / transactions.

Application of additional measures like gathering information from publicly
available source or otherwise
Review of the proposal / contract by senior official.
Prohibition of acceptance of proposal from customers residing in FATF deficient
countries.
Close monitoring of cash remittances
Extra care and due diligence where Form 60 or 61 have been submitted
Cashless settlement of claims, payments directly to bankers, dealers/ repairers,
employers, claimants through NEFT/ RTGS
11/15/15
20

Advisors / Specified Persons being the front end support
and preliminary underwriters, will have to indicate any
behavioralaspects of a Customer that are found to be
suspicious at the time of their interaction in the Agents
Confidential Report / SP report. Depending on the Sum
Assured and profile, Moral Hazard Report from the Sales
hierarchy within SUD Life will be obtained.
11/15/15
21
Procedure for Determination of Beneficial Owner

Customers other than individuals or trust
Where a customer is other than individual or trust, SUD Life
shall identify the beneficial owners of the customers & take
reasonable measures to verify the identity of such persons
through following
juridical person is a company - Ownership >25% of
Where ainformation's.
shares or capital
Customer
other
than
Individual
or
Trust
(Indentifie
d
basis
controllin
g
ownership
interest)
Where a juridical person is a partnership firm - Ownership >

15% of capital or profit
Where a juridical person is a unincorporated association ownership > 15% of property or capital
Incase of any doubt to above or whether no person exerts
control through ownership interests, the identity of the natural
person exercising control over the juridical persons through
other means. Control through other means can be exercised
through voting rights, agreements, arrangements etc.
11/15/15
Where no natural person is identified above, the identity of the

relevant natural
person
who holds
of senior
22
Sales Training
-AML Presentation
Ver 1.9 the position
Procedure for Determination of Beneficial Owner

Continued
Customers other than individuals or trust
continued
Through the identity of the settler of the trust, the trustee, the
Customer is
protector, the beneficiaries with 15% or more interest in the
Trust
trust and any other natural person exercising ultimate effective

control over the trust through a chain of control or ownership
Exceptions
Where owner of controlling interest is a listed company or is a

majority owned subsidiary of such company.
Applicability
The above shall be applied for premium threshold as under :

Keyman contracts -Rs. 1 lac / policy
Partnership contracts - Rs. 2 lac / policy
Others (HUF / Trust) - Rs. 1 lac / policy
In cases of employer-employee policies, threshold laid above

are as relevant to the constitution of the juridical person
taking insurance contact.
11/15/15
23
Risk Classification
SUD Life will carry out risk assessment to identify,
assess and take effective measures to mitigate its
Money Laundering and Terrorist Financing risk for
client,
countries
or
geographic
location
and
products, services, transactions or delivery channel.
The risk assessment shall be documented; consider

all the relevant risk factors before determining the
level of overall risk and the appropriate level and
type of mitigation to be applied; be kept up to date;
and be available to competent authorities and selfregulating bodies.
11/15/15
24
Risk Classification Continued

Risk profile of product / features
High Risk (Vulnerable features):
Free Look Option
Top-up Premium
Partial Withdrawal
Single Premium Payment
Borrowing on Policy
Assignment to third parties
11/15/15
25

Risk profile of product / features
Low Risk:
Micro Insurance Products
Pure Risk Cover
Pension and Annuities contract
Group Insurance Product
Health Products
Reinsurance and Retrocession contracts.
11/15/15
26

Risk Profile of the
Customer
In the context of very large base of insurance
customers and the significant differences in
the extent of risk posed by them.
IRDA has instructed all insurers to classify their
customers into different risk categories:
High Risk Profile
11/15/15
Low Risk Profile
27

High Risk Profile:
A High Risk profile customer would typically consist of
customers who by nature of their occupation, place of
residence
or
any
other
characteristics
are
more
vulnerable to money laundering. Some examples of such

cases have been listed below:
Customers involved in a business that handles large amounts of cash.
For example, Scrap dealers, Persons engaged in Real Estate business,
businesses with a complicated ownership structure that could conceal
underlying beneficiaries.
Non-resident Indians and Foreign residents
Politically Exposed Persons (PEPs).
High Networth Individuals (HNI) (Generally, individual policyholders
who pay a premium above Rs.5 lakhs per annum on all classes of
11/15/15
28
igh Risk Profile continued

Politically Exposed Person (PEP)
Domestic
PEPs
are
individuals
who
are
or
have
been
entrusted
domestically with prominent public functions, for example Heads of State

or of government, senior politicians, senior government, judicial or military
officials, senior executives of state owned corporations, important political
party officials. Persons who are or have been entrusted with a prominent
function by an international organization refers to members of senior
management, i.e. directors, deputy directors and members of the board or
equivalent functions. The definition of PEPs is not intended to cover
middle ranking or more junior individuals in the foregoing categories.
11/15/15
29

Enhanced due diligence will be done in case of high risk
profile customer.
Proposals of high risk customers should be approved by head
underwriting.
All PEP cases (includes close relatives & where PEP is the ultimate
beneficial owner) to be approved by Sr. Management not below Head
Underwriting / Head Risk Management.
PEP MHR needs to be signed and submitted by AVP for all PEP cases.
If the ongoing risk management procedures indicate that the customer
or beneficial owner is found to be, or subsequently becomes a PEP,
senior management approval will be obtained on this business
relationship.
11/15/15
30

Other Risks
Mode of premium remittances e.g. cash, banking channels, credit cards
Type of premium remittances opted: Single premium / Regular premium
Sources of premium funding, especially when it is being funded by a third
party. However, underlying risks minimize in relationship between payor
and insured as under:
o Close family relationships,
o Debtor-Creditor relationships,
o Employer-employee relationships
o Parent-subsidiary relation
o Consignor-consignee relation
11/15/15
31
Risk Profile of the Customer

Identify High Risk Profile
Customers
Mr. Ashish Parekh- A Famous

Builder
Mr. Vikas Shah A Stationery Dealer
Ms. Lalita Gandhi A Youth Leader
Mr. Shahid Kumar Senior politician

Ms. Jiya Rai - Actress
11/15/15
32

Check the answers
Mr. Ashish Parekh- A Famous
Builder
Ms. Lalita Gandhi A Youth Leader
Mr. Shahid Kumar Senior politician
11/15/15
33
Risk Profile Customer

Identify Low Risk Profile Customers
Mr. Vidyadhar Sule - A Farmer
Mr. Kartik Mehera A HNI
Mr. Sharad Sathe A Government

Clerk
Ms. Kavita Patil A Municipal
School Teacher
11/15/15
34
Check the correct answers

Mr. Vidyadhar Sule - A Farmer
Ms. Kavita Patil A Municipal

School Teacher
Mr. Sharad Sathe A Government

Clerk
11/15/15
35
Regulatory Reporting
11/15/15
36
Any suspicious transactions that are identified will be
reported to the FIU-IND within 7 working days of
identification in the prescribed format.
Besides the above, employees / sales personnel will be
responsible to report any suspicious transactions that
are noticed by them to the Principal Compliance Officer
at compliance@sudlife.in
11/15/15
37
Illustrative list of Suspicious Transactions, requiring further scrutiny:
Customer (including assignees, where applicable) whose identity matches with
any person whose name figures in the list of banned persons and entities
Cash transactions for payment of premium and top-ups of Rs. 5 lakhs and above.
Multiple DDs each denominated for less than Rs. 50,000/Frequent free look cancellations by customers
Single policy free look cancellation
Assignments to unrelated parties without consideration (or inadequate
consideration)
Request for purchase of insurance policy considered beyond ones apparent need
Unusual termination of policies and refunds
Frequent requests for change in addresses
Borrowing the maximum amount under an insurance policy soon after buying it
Inflated or totally fraudulent claims
Overpayment of premiums with a request for refund of the amount overpaid
*Note: The list is only illustrative and not

exhaustive.
11/15/15
38
Other FIU-IND Reporting
IRDA has mandated compulsory reporting to the FIU-IND for:

Cash Transactions: All integrally connected cash transactions
above Rs 10 lakhs in a month.
Reporting of receipts by Non-Profile Organization - All
transactions,
involving receipts
by non-profit organization
(either in the form of assignments and /or in the form of top-up

remittances) of value more than Rs. 10 lacs, or its equivalent in
foreign currency, should be reported to FIU-IND by 15th day of
the next succeeding month
Reporting of Counterfeit Currency / Forged Bank notes
(CCR) - All cash transactions where forged or counterfeit
currency notes or bank notes have been used as genuine and
where any forgery of a valuable security or a document has
11/15/15
taken
Sales Training
Presentation Ver 1.9should39 be reported
place facilitating
the -AML
transactions
Exceptions to AML
Anti Money Laundering guidelines are applicable to
all
insurance business except:
Standalone medical / health insurance products
Group insurance business
AML does not apply to the above mentioned

products because:
Lower risk profile of these products
Event based payouts
More stringent
underwriting norms
11/15/15
40
The Financial Action Task Force (FATF)

FATF provides list of countries which are not compliant with FATF (Financial
Action Task Force) recommendations. These countries are termed as AML/
FATF deficient countries.
List of Countries* (updated as on August 2015)

Iran
Bosnia and
Herzegovina
Sudan
Democratic Peoples
Republic of Korea
(DPRK)
Algeria
Ecuador
Syria
Guyana
Uganda
Eucador
Laos and Lao

PDR
Yemen
Myanmar
Panama
Angola
Afghanistan
Papua New
Guinea
*Note: List of FATF Deficient Countries will be provided by the Compliance Team
to operations for monitoring. Such list is updated on a continuous basis.
11/15/15
41
KYC Requirements
Photo ID Proof
Address Proof
Income Proof
Source of Fund
List of acceptable KYC documents shall be covered in subsequent slides.
11/15/15
42
KYC Requirements (Continued)

Photo ID Proof
It is mandatory to establish customers identify in respect of all
insurance contracts. Life Assured or Proposer has to sign across
the photograph on the proposal form.
Passport
PAN Card
Voters Identity Card
Driving License
Ration Card (bearing a photograph of the Customer)
Letter from a recognized public authority or public servant verifying the
identity of the customer
Written confirmation from the banks where the prospect is a customer
Employee identity card of a listed company or public sector company

Personal identification and certification by SUD Life employees for
identity of the prospective policyholder.
Board (e.g. SSC, HSC, SSLC, etc) or University mark sheets bearing
photo.
University mark sheet bearing photo issued to student.
11/15/15
43

Photo ID Proof
continued
Employee ID cards bearing photo issued by Central or State Govt.
Kisan credit card bearing photo
Bank pass book bearing photo
Defense ID card / Defense dependent's card / Ex-serviceman card bearing photo
Identity cards bearing photo issued by professional bodies such as:

Bar Council
Indian Medical Association
Institute of Chartered Accountants of India
Institute of Company Secretaries of India
Institute of Cost & Works Accountants of India
Senior citizen card bearing photo
Pension ID card issued by Stat e/ Central Govt. bearing photo.
NREGA Card issued by State govt.
UID Card is being accepted for Address and ID proof
Officially valid document notified by Central Govt.
The List is illustrative and not exhaustive
11/15/15
44

Address Proof
It is mandatory to provide customers permanent and current
address proof in respect of all insurance contracts. The address
proof submitted must match with
communication and / or
permanent address given in the proposal form.
Telephone bill including mobile, landline, wireless etc type of
connections,
not older than 6 months from the date of insurance contract.
Letter from any recognized public authority or public servant
Credit card statement
Electricity bill
Passport
Driving License
Ration card
Valid lease agreement along with rent receipt, which is not more
than 3 months old
Employers certificate for residence proof. (Certificates of employers
who have in place systematic procedures for recruitment along with
maintenance of mandatory records of its employees)
11/15/15
45

Address Proof
continued
Current passbook (updated to previous month) & Current

Statement
of bank account (as downloaded) with details of permanent /
present residence address.
Written confirmation from the banks where the prospect
is a customer.
Consumer Gas connection card / book
(with transactions within the last 3 months)
Gas Bill / Gas connection letter (less than 3 months old)
Water Tax
(less than
Bill mentioning flat number or owner's name

3 months old)
Voters ID
Govt. Service ID Card
Officially valid document notified by Central Govt.

11/15/15
46

Income Proof
Form
16
Latest copy of Income tax assessment orders /

Income Tax returns slips
Form 16 in case of employed individual
Salary slips from employers (within last 3 months)
For present employment of 3 months or more.
Latest copy of Audited Company accounts
CA
c
Certifi
ate
Latest copy of Audited firm accounts and Partnership deed

Latest copy of Audited proprietorship profit & loss account
Latest copy of Copies of form no. 10CCAC under section 80 HHC
of IT ACT 1961 for export income
11/15/15
47

Income Proof
continued
Form
16
Employers Certificate
Appointment letter mentioning salary + salary slip - For present
employment of less than 3 months.
Chartered Accountant's certificate
Bank cash flow statements, pass books
Registration certificate (RC) book for transport fleet owners
CA
c
Certifi
ate
Mandi receipt of sale of agricultural crop + Agricultural land details

& income assessments
Agricultural Income Certificate
Agricultural-land details & Income assessments

11/15/15
48
Let Us Check!
Dayals Story
He wants to buy
3 life insurance
policies of rupees
10 lacs each
(single premium)
through
Bancassurance
Channel.
Mr. Dayal is an
owner of Grand
Dine hotel
He has
recently sold
his land for
Rs. 50 lacs.
11/15/15
He wants to
make cash
payment.
49
Let Us Check!
What should the company do in such
cases?
Accept the cash
Cash can not be accepted, has to

pay through cheque or demand
draft
*Note - Cash can be accepted under Agency Channel.
11/15/15
50
Let Us Check!
Dayals Story (Continued)
His bank statement
shows an entry of
Rs. 40 lacs
deposited on a
single day on his
bank account 2
days before the
date of proposal of
policy
He submits IT
return as
income proof
and bank
statement.
As per IT
return his
annual
income is 10
lacs only .
11/15/15
He maintains an
average balance
of
Rs. 5,00,000
since past 6
months.
51
Let Us Check!
In this case What can be the additional
requirement can be called for?
Self declaration is to be submitted
Policy will be rejected immediately

Source of fund is required where he
can provide the proof of sale of land
11/15/15
52
Let Us Check!
Unfortunately
, after 6
years, Mr.
Dayal dies
due to a road
accident.
His wife has

claimed for the
policy money.
11/15/15
53
Let Us Check!
What will be the AML & KYC requirements at
this stage?
Nominee has to provide the
relationship proof with deceased
life assured along with the power
of attorney
KYC documents are required like
address proof & photo ID of the
nominee.
11/15/15
54
Please Do Remember !
Sales staff / field force are front line staff (preliminary underwriters) who actually
see and meet the policyholder in person.
Document information about the policyholder mostly those which are intentionally
not disclosed by the customers for. e.g. customer is an active PEP or close relative
of PEP. Such disclosures are required to be made in the Advisor Confidential
Report(ACR).
Adverse media or negative news is unfavorable information that can be found in a
variety of reference sources. The risks associated in conducting business with such
persons or companies which have an adverse media profile are many. Again since
the field force being the front line staff, they will be able to provide with such
important information about the customer in the ACR. For e.g. individual /
company is associated in criminal activity, scams, financial frauds, was sentenced
to jail / bar or currently serving for courts hearing etc.
11/15/15
55
Summary
In this session you have learnt:
What is Money laundering?
The process of money laundering.
Know Your Customer (KYC)
Money laundering regulations.
The concept of know your customer.
Impact of money laundering on insurance business.
Different categories of risk profile of customers.
Some of the suspicious transactions.
Anti money laundering and know your customer
requirements.
Obligation of SUDLife
Financial Action Task Force (FATF)
Risk assessment
11/15/15
56
Disclaimer
This material belongs to the Sales Training Team of Star Union
Dai-ichi Life Insurance Company Limited.
Any unauthorized use, reprint or circulation is prohibited.
For Internal Circulation Only.
Star Union Dai-ichi Life Insurance Company Limited.
(Registration No. 142.), 11th Floor, Raghuleela Arcade,
IT park, Sector 30 A, Opp. Vashi Railway Station,
Vashi, Navi Mumbai 400703
Insurance is the subject matter of the solicitation.
11/15/15
57
11/15/15
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AML Presentation &amp; KYC Ver 1.9

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Anti Money

Sales Training -AML Presentation Ver 1.9

Moral Hazard Report (MHR)

Process of Money Laundering

Enhanced Due Diligence

Obligation of SUD Life

Procedure for identification of

Know Your Customer (KYC)

Impact of Anti Money Laundering

Sales Training -AML Presentation Ver 1.9

Money Laundering is the processing of DIRTY

Dirty Money are proceeds derived from criminal

Criminals want the money to look like it came

Sales Training -AML Presentation Ver 1.9

Anti Money Laundering Regulations

mandatory for all insurance companies

Sales Training -AML Presentation Ver 1.9

Process of Money Laundering

Sales Training -AML Presentation Ver 1.9

Process of Money Laundering (Continued...)

Sales Training -AML Presentation Ver 1.9

Process of Money Laundering (Continued...)

Layering: This stage concentrates on separation of proceeds from

Sales Training -AML Presentation Ver 1.9

Process of Money Laundering (Continued...)

Integration: At this stage, the laundered proceeds are placed

Sales Training -AML Presentation Ver 1.9

Process of Money Laundering (Continued...)

Sales Training -AML Presentation Ver 1.9

Obligation of SUD Life

Sales Training -AML Presentation Ver 1.9

AML/ KYC Requirements

Sales Training -AML Presentation Ver 1.9

AML/ KYC Requirements

Where annualized premium is equal to or more than Rs. 50,000, it is

Sales Training -AML Presentation Ver 1.9

AML/ KYC Requirements

separately) is equal to or more than Rs.1 lac, proof of income is

KYC is to be carried out at times when the top up remittance is

Any change in the customers recorded profile that comes to

normal and expected activity of

require KYC exercise to be taken afresh.

Sales Training -AML Presentation Ver 1.9

AML/ KYC Requirements

(An assignment transfers the rights, title and

interest of the assignor to the assignee)

spouse / children / member of a Hindu Undivided Family) or to

Sales Training -AML Presentation Ver 1.9

AML/ KYC Requirements

All residential address change requests to be submitted with proof of new

Sales Training -AML Presentation Ver 1.9

AML/ KYC Requirements

Sales Training -AML Presentation Ver 1.9

Know Your Customer

Know Your Customer

Sales Training -AML Presentation Ver 1.9

Enhanced Due Diligence

Details of sources of funds for all policies to be obtained,

Sales Training -AML Presentation Ver 1.9

Enhanced Due Diligence Measures

More frequent reviews of the customers activities / profile / transactions.

Sales Training -AML Presentation Ver 1.9

Moral Hazard Report (MHR)

Sales Training -AML Presentation Ver 1.9

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