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.

Template for Coverholder Compliance Manual

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.

SanctionsSearch Brochure

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.

Lloyd’s are in the process of devising completely new financial crime e-learning modules and are currently in the demo stages.

Further to this, Lloyd’s will not be able to supply records confirming the completion of modules as this information is not now being provided by the third party who originally serviced the financial crime modules.

For further information regarding financial crime and sanctions please refer to the following links:

Anti-money laundering and international sanctions guidance for Coverholders

Financial crime, international sanctions and regulatory risk

Y4727 - Financial Crime and Sanctions Guidance for Coverholder Business

For any enquiries relating to financial crime and sanctions, please email

  • FAQs

    Q: I don't know my PIN number from ATLAS or I wish to conduct the modules prior to my PIN being established.

    A: A coverholder should quote its PIN (6 numbers) when undertaking the training module. Employees of managing agents should use the PIN 222222 if they wish to review the modules. Lloyd’s brokers should use the PIN 333333 if they wish to review the modules (brokers who are also coverholders should, however, use their coverholder PIN). If you are unsure of you PIN please use bulk PIN 555555 however so Lloyd's is able to report to who has conducted the training modules it is strongly advised that a coverholders actual PIN is used.