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.