Guidance on Insurers

52. With regard to Insurers, the following "Know Your Customer" verification and identification set out in this section should be taken into account.
53. An Insurer undertaking verification should establish to its satisfaction that every verification subject exists. All verification subjects of joining applicants for Insurance Business should normally be verified. In the case of arrangements such as trusts, nominee companies and front companies, verification should include an assessment of the substance of the arrangement, for example in relation to settlors, trustees and beneficiaries.
54. An Insurer should carry out verification in respect of the parties entering into the Contract of Insurance. On some occasions there may be underlying principals and, if this is the case, the true nature of the relationship between principals and the policyholders should be established and appropriate enquiries performed about the former, especially if the policyholders are accustomed to acting on their instructions. 'Principal' should be understood in its widest sense to include, for example, Beneficial Owners, settlors, controlling shareholders, Directors and major beneficiaries.