SAIA

South African Insurance Association

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Update on the Financial Intelligence Centre’s (FIC) proposal to include non-life insurers as Accountable Institutions- SAIA Bulletin July 2019

1. Risk assessment being conducted by Deloitte:

Deloitte hosted workshops with smaller work groups, which included insurers and intermediaries in the non-life insurance industry, to understand their respective businesses and identify areas where possible money laundering and/or terrorism financing risks may arise, if any.

The information obtained from these workshops will further inform the questionnaire being developed by Deloitte that will be sent out to the non-life insurance industry. This questionnaire will form the basis of the risk assessment. Deloitte is in the process of finalising the questionnaire following consultation with industry stakeholders.

2. FIC “go-AML” Reporting Tool:

Following the SAIA-led NLIWG’s engagements with the FIC, it was agreed that the FIC’s current reporting tool “go-AML” would be the suitable and secure method to be utilised for information reporting/submission purposes for non-life insurers whilst the risk assessment is being conducted. The non-life insurance industry is, therefore, entering into an arrangement for sharing information with the FIC, on a voluntary basis. However, the FIC has requested that the widest possible range of non-life insurers participate as this will assist in informing the FIC’s position on the inclusion of non-life insurers as Accountable Institutions under the FIC Act. Once the risk assessment is complete, a decision on the continuation of the sharing of information will be taken by the FIC, amongst others.

SAIA requested members to advise whether they would be registering on “go-AML” following a FIC workshop held on 10 May 2019 on “go-AML”.

Of the 28 members that responded, 11 members are already registered by virtue of their life licences whilst 17 members indicated their intention to register. The FIC will assist members with the registration process but advised that it is necessary to register separately for the non-life licence in light of the different requirements on the system for life insurers by virtue of being Accountable Institutions.

For more information contact Easvarie Naidoo, SAIA Senior Legal Manager: Easvarie@saia.co.za