Anti-Money Laundering Requirements for Insurance / Reinsurance Intermediaries 

Insurance Intermediaries are “designated bodies” for the purposes of regulation 3(7) of S.I. No. 104 of 1995 / Criminal Justice Act 1994 (Section 32(10)(a)) Regulations 1995 and also for the purposes of  paragraph 3(b) of the schedule to S.I. No. 3 of 2004 / Criminal Justice Act 1994 (Section 32) (Prescribed Activities) Regulations 2004.

This means that Insurance Intermediaries are obliged, when providing their Insurance Mediation services, to:

• Identify customers and retain certain records.
• Report to the Garda Síochána (Irish police force) and Irish Revenue Commissioners any suspicion that a money laundering or financing of terrorism offence has been or is being committed in relation to their business.

As designated bodies Insurance Intermediaries must:

• Maintain adequate records of transactions to allow the Financial Regulator to monitor compliance with section 32(9)(a) and (b) of the Criminal Justice Act 1994
• Establish and document adequate and appropriate policies procedures to assist staff to identify money laundering activity - section 32(9B)(a), (b) and (c) of the Criminal Justice Act 1994 
• Establish clear reporting procedures to assist staff and management to comply with the reporting obligations set out in section 57 of the Criminal Justice Act 1994

Applicable guidance notes depending upon the nature and scope of their proposed business:

          AML Guidance notes for Financial institutions

          AML guidance notes for Life Assurance Companies and Insurance Intermediaries  

Insurance Intermediaries offering services in relation to non-life insurance

Insurance intermediaries offering services solely in relation to non- life insurance products do not currently fall into the designated body criteria.