Anti-money laundering procedures


04-June-2012

As the main players in the insurance field in Seychelles, we believe in upholding the integrity of our business for the benefit of all our stakeholders, policyholders and shareholders;
therefore, the implementation of and adherence to effective customer due diligence and vigilance procedures play a central role in the prevention of money laundering and terrorist financing practices. In addition to reducing the risk of exposure to such activities, effective customer due diligence practices also protect insurance entities against a range of other potentially damaging risks including reputational risk, legal risk and the risk of regulatory sanction
Anti-money laundering and combating terrorist financing (“AML/CFT”) initiatives have been developed both nationally and internationally over the past 10 years.

At international level, the Financial Action Task Force (FATF) forty recommendations and nine special recommendations on terrorist financing are perhaps the most influential supra national initiatives in this arena. Seychelles will adhere to and implement the FATF recommendations through its membership to Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) in order to combat money laundering.  This effort includes coordinating with other international organisations concerned with combating money laundering, studying emerging regional typologies, developing institutional and human resource capacities to deal with such issues.  This will also mean the coordination of technical assistance where necessary.  ESAAMLG enables regional factors to be taken into consideration when implementing anti-money laundering measures.

At the national level, a number of legislative changes have been introduced to enhance the existing AML/CFT legal framework to cater for the implementation of the FAFT 40 recommendations.

For instance, the Anti-Money Laundering Act 2006 (‘the Act’), Anti-Money Laundering (Amendment) Act 2008, The Prevention of Terrorism Act 2004 were-enacted to tally with international norms.

The future success of Seychelles as a centre for the provision of financial services depends (inter alia) upon the maintenance of its reputation of probity. It is therefore vital that insurance entities in Seychelles exercise appropriate care to avoid entering into a business relationship with anyone who is a criminal or intends to launder crime monies or engages in terrorist financing.

We have, therefore, joined our efforts with the relevant government authorities, namely the Financial Intelligence Unit, operating under the auspices of the Central Bank of Seychelles, to issue this communiqué.  It is to inform all our current and prospective customers of the regulatory demands to enable you to assist us in our duty to comply with the local laws and regulations and ultimately thrive to uphold our reputation internationally as a sane financial services hub.

The law requires that the insurance entities adopt internal AML/CFT policies, establish internal procedures and allocate responsibilities to ensure that these policies and procedures are introduced and maintained accordingly.

When establishing a business relationship with an applicant, insurance entities must apply appropriate customer due diligence risk profiling procedures.  Such measures will include the identification of the applicant and its verification. Insurance entities must take all reasonable measures to complete all CDD requirements for all applicants prior to establishing a new client relationship and prior to providing any financial service.

For this purpose, henceforth all our customers will be required to submit some primary identity documentation that would help us in our risk profiling procedures and eliminate any suspicions of their association with or involvement in money laundering. Please note that the insurance entity may require additional documentation to establish the minimum criteria.

A.    INDIVIDUAL CLIENTS
1. Verification of identity of natural persons;

• Current valid passports
• National identity cards
• Current valid driving licences
2. Verification of address of natural persons:
• A recent  (not older than three months) original utility bill- telephone/water/electricity
• A recent original bank or credit card statement
• A recent original bank reference


B. LEGAL ENTITIES - Private companies/societie /trust/partnership

1. Existence and identity of the legal person or arrangement:
• Appropriately certified copy of the certificate of incorporation or registration or trust deed
• Details of the registered office and place of business;
• The identity of the principals of the company – directors, major shareholders, trustees, partners as appropriate;
• The comfort that any person who purports to act on behalf of the company is so authorised and identifying that person.

C.        Source of funds/property

A necessary pre-requisite for the identification and prevention of money laundering, is to understand the origin or provenance of property that forms part of any arrangement, both at the outset of a client relationship and for its duration.

Insurance entities may therefore request appropriate documentation to establish the source of property. There will be no requirement for the insurance entity to verify the information supplied, where this information is consistent with that already held by the insurance entity in relation to an applicant for business and shows no abnormal or potential suspicious activity within the context of the product or service being provided,.

In line with the above, we rely and thank you for your utmost collaboration with us to enable us to comply with our legal requirements.

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