Financial Crime & Sanctions
The following links provides guidance in relation to financial crime and Lloyd’s expectations of Coverholders in fulfilling their obligations.
It is important that Coverholders understand the risks facing the insurance industry from financial crime and increased regulatory/legislative burdens. It is also important to understand their obligations to mitigate those risks.
Financial crime includes money laundering, bribery and corruption, and failure to adhere to international sanctions regimes. Lloyd’s requires both managing agents and Coverholders to implement proportionate systems and controls to appropriately manage the risk of financial crime within a business.
Amongst other controls, Coverholders can help effectively mitigate their financial crime risk by conducting sanctions screening as part of their due diligence. There are many screening tools available for Coverholders to use. Lloyd’s has negotiated preferential rates with 'SanctionsSearch', to offer Coverholders an effective screening product at a low cost. Please see the brochure below for more information.
Based on discussions with Managing Agents, Coverholders are required to:
- Have proportionate written procedures regarding anti-money laundering which should cover staff training and awareness, record keeping and recognising and reporting suspicious transactions.
- Ensure adequate controls are in place to comply with local and UK issued sanctions.
- Comply with the UK Bribery Act (as agreed with Managing Agents well as any local anti-bribery and corruption legislation.
Under the UK Bribery Act, a Coverholder is considered to be an associated person of the Managing Agent and can therefore create criminal liability for the Managing Agent.
For any enquiries relating to financial crime and sanctions, please email: