Title
KYC and CDD Guidelines for Insurance Firms
Law
Ic Circular Letter No. 15-2007
Decision Date
Aug 7, 2007
The Insurance Commission's guidelines streamline Know Your Customer (KYC) and Customer Due Diligence (CDD) requirements for insurance transactions, simplifying compliance for low-risk customers while ensuring adherence to anti-money laundering regulations.
A

Customer Identification and ID Requirements

  • First-time clients must present an original and submit a copy of at least one valid, highly credible photo-bearing ID issued by official authority.
  • Examples of highly credible IDs include passports, driver’s licenses, PRC ID, police clearance, voter’s ID, senior citizen’s card, government IDs, and others as listed.
  • Substitute IDs such as birth certificates or private company IDs allowed if no credible photo ID is available initially, but must be replaced by a credible photo ID during policy duration.
  • Significant transactions require updated customer records, while policies with no significant transactions need record updates every two years.
  • If photocopying is unavailable, the agent must certify witnessing the original ID and ensure subsequent photocopies are submitted.
  • Compliance with minimum KYC information as per Revised IRR Rule 9.1.c is mandatory; insurers may require multiple IDs to meet requirements.

Telemarketing, Direct Marketing, and SMS Insurance Sales

  • No face-to-face meeting required for telemarketing, SMS, direct mail, or broadcasting sales.
  • Insurance premiums must be minimal: annual premium not exceeding Php 50,000 or single premium not over Php 125,000.

Group Policies, Worksite Marketing, and Specific Insurance Products

  • Group policies: Employers/entities holding the policy are corporate clients required to submit KYC/CDD documents; individual members’ details submitted via certified list.
  • Salary allotment/worksite marketing: Employer considered corporate client; provides KYC documents; existence of employer-employee relationship confirms identity and income legitimacy.
  • Personal accident, health, credit life, term policies without savings component: Application info used for underwriting and policy maintenance suffices for KYC/CDD; duplicate verification not required.

Bancassurance Transactions

  • Insurance sales through banks are exempted from separate KYC as bank customers already undergo KYC/CDD.
  • Waiver of KYC requirements upon notarized Bancassurance Agreement with warranty clause or sworn certification by the partner bank confirming KYC compliance.

Brokered Transactions

  • KYC responsibilities primarily rest with insurance brokers who are covered entities under AMLA.
  • Brokers must issue sworn KYC-compliant certification for accounts handled.
  • Insurance companies retain their own KYC responsibilities despite broker’s certification.

Microinsurance

  • Reduced KYC requirements for microinsurance where daily premium does not exceed 10% of daily minimum wage and coverage is less than 500 times the daily minimum wage.
  • Simplified filing of application with minimum client information is sufficient.
  • Applies to non-life minor line products with similar premium and coverage limits.

Non-Cash Transactions and Reporting Obligations

  • Insurance companies relieved from reporting non-cash transactions (e.g., claims settlement via checks) to prevent redundant reporting as banks report these transactions.
  • Insurance companies must still report suspicious transactions and comply with KYC/CDD and record-keeping obligations.
  • Insurers must establish reliance levels for third parties (banks, employers, brokers) in applying these guidelines.

Effectivity

  • Circular takes effect immediately from August 7, 2007.
  • Supersedes all inconsistent Insurance Commission circulars, rules, and regulations.
  • Emphasizes guidance for IC-covered institutions to ensure compliance and efficient implementation of KYC/CDD requirements without impeding business operations.

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