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. 

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

  • e-Learning Training Module

    This training module has been developed in conjunction with the market and Its purpose is to ensure Lloyd’s market participants, no matter where they are located, understand; the basis of the UK Bribery Act 2010 (Bribery Act), particularly commercial bribery; their obligations in respect of the prevention of money laundering and reporting of suspicious transactions when conducting business on behalf of Lloyd's syndicates; and their obligations regarding compliance with international sanctions.

    Note that this training is not mandatory, but the module should be considered a useful tool in ensuring that Market participants understand Financial Crime Prevention.
    Please provide the relevant link below to those coverholders and TPAs that you wish to undertake this training, considering whether it is more appropriate for this communication to be sent via the broker or direct to the coverholder.

    Note that where individuals have already registered for the Complaint handling or Conduct risk training, they will not need to sign up again as these modules will automatically be available within their profile.

    Coverholders

    Coverholders should use the following link:

    eLearning for Coverholders

    Please note coverholders are required to enter their PIN, they will not be able to complete the registration process without this.

    TPAs

    TPAs should use the following link:

    eLearning for TPAs 

    Once TPAs have been issued with a PIN, they will be required to enter this to complete the registration process but this is not yet required.

    Managing Agents and Others

    Managing agents and all other users should continue to use link:

    eLearning for Managing Agents and others

    Lloyd’s Delegated Authority team are currently working on making  reports available to managing agents to show which of their coverholders and TPAs have completed the training but until this is available, please email your request to complaints-enquiries@lloyds.com with details of the coverholders and TPAs for which you require this information.