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By Pierre KIRSCH, Partner and Frauke ORTMANN, Director, PwC Luxembourg
Life insurance companies and intermediaries are subject to Anti-Money Laundering and terrorist financing (AML/CFT), as well as Know-Your-Customers (KYC) and Know-Your-Transactions (KYT) obligations and therefore have to collect and review various documentation from their clients to ensure they have a clear understanding of their clients’ activity, source of wealth and source of funds and that there is no risk of money laundering. During the onboarding process of a policyholder, the questionnaire issued by the Commissariat aux Assurances (CAA) in its Circular Letter 18/9 has to be considered for the AML/KYC assessment.
Indeed, since the 1st of September 2019, life insurance...
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