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 has developed three on-line training modules to guide Coverholders through Lloyd's expectations on financial crime. The purpose of these modules is to clarify Lloyd's expectations and encourage a consistent market approach to meeting these expectations. Underwriters and Brokers are asked to ensure that the key personnel at Coverholder's offices complete these modules. 

The modules are available here:

Lloyd’s will keep a running list of those who have completed the modules and we can provide this list to underwriters and brokers on request.

Coverholders can access the modules by using their PIN. Full details can be found in the following Market Bulletin:

Y4577 - Financial Crime

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 regulatory@lloyds.com

  • 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.