Question & AnswerQ&A (IC CIRCULAR LETTER NO. 15-2007)
The main goal is to rationalize the Know Your Customer (KYC) rules and simplify the Customer Due Diligence (CDD) requirements to avoid impeding insurance transactions while achieving the objectives of the Anti-Money Laundering Act (AMLA) of 2001 and its Revised Implementing Rules and Regulations (IRR).
Highly credible photo-bearing IDs include Passport, Driver's License, PRC ID, Police Clearance, Postal ID, Voter's ID, Photo-Bearing Barangay ID/Certification, GSIS e-Card, SSS Card, PhilHealth Card, Senior Citizen's Card, OWWA ID, OFW ID, Seaman's Book, Alien Certificate of Registration/Immigrant Certificate of Registration, Government Office IDs, IDs issued by government instrumentalities, IDs/Certifications from NCWDP and DSWD, Firearms License, Bureau of Internal Revenue ID, Photo-Bearing Credit Card, and Photo-Bearing Health Card issued by Health Maintenance Organizations.
Yes, substitute IDs like birth certificates or private employment IDs without photos are allowed if the applicant cannot produce any highly credible photo-bearing ID during initial contact, provided the agent verifies the identity and requires the photo-bearing ID during the policy duration or when filing claims.
For policies without significant subsequent transactions, KYC document updates must be made at least once every two years.
No face-to-face meeting is needed for telemarketing or selling via SMS provided the premium is minimal—annual premium not exceeding Php50,000 or single premium not over Php125,000.
Group policies taken out by employers or entities require the employer/entity to be a corporate client submitting KYC/CDD documents. The employer is responsible for submitting a certified list of eligible members and verifying their identification documents.
Since the employer-employee relationship establishes identity and income source, the employer is considered the corporate client required to submit KYC documents. The net-take-home pay rule helps ensure affordability and legitimacy of funds.
KYC requirements are waived for bank clients applying for insurance from bancassurance partners if there is a notarized Bancassurance Agreement or a sworn certification by the bank that the client has undergone KYC/CDD at the bank.
Insurance brokers are primarily responsible for knowing their clients and conducting CDD as they are covered entities under the AMLA. A sworn KYC-compliant certification issued by brokers suffices for insurance companies, though companies retain their own KYC responsibilities.
For microinsurance with premiums not exceeding 10% of the daily minimum wage and coverage not more than 500 times the daily minimum wage, filing a duly accomplished application with minimum client information is sufficient, also applying to non-life minor line products.