5 CUSTOMER DUE DILIGENCE AND SCREENING PROCEDURES
5.1 Screening of customers11 should be carried out against relevant ML/TF information sources, which include designated names of individuals and/or entities within:
(a) the lists and information provided by the Authority or other relevant authorities in Singapore in relation to ML/TF risks;
(b) the First Schedule of the TSOFA; and
(c) the MAS TFS Regulations.
5.2 In the context of direct insurance business, the screening of customers should include the screening of policy owners, insureds and claimants. In cases where an insurer has assessed the policy owner or insured to be of a higher ML/TF risk, the insurer should also screen the substantial shareholders (direct and indirect), beneficial owners, natural persons appointed to act on behalf of the customer and directors, if any, of the policy owner or insured.
5.3 In the context of reinsurance business, the screening of customers should include the screening of cedants and claimants12. Underlying insureds should also be screened in cases where they are made known to the reinsurers. In cases where a reinsurer has assessed the cedant or underlying insured to be of a higher ML/TF risk, the reinsurer should also screen the substantial shareholders (direct and indirect), beneficial owners and directors, if any, of the cedant or underlying insured.
5.4 Screening of customers should be conducted at the following points in time:
(a) before establishing business relations for new customers, otherwise as soon as reasonably practicable thereafter;
(b) prior to renewing business relations with existing customers;
(c) on a regular basis after the establishment of business relations13;
(d) when there are changes made to the lists14 mentioned in paragraph 5.1 above;
(e) before making claim payments to claimants15.
5.5 For the purposes of screening, the insurer should minimally, either:
(a) subscribe to a commercial sanctions database; or
(b) maintain an internal database containing the names of designated individuals
5.6 The screening database(s) (i.e. commercial sanctions database and/or internally-
maintained database) and procedures adopted by an insurer should be effective in identifying individuals and entities with adverse information, as well as designated individuals and entities as defined in the First Schedule of the TSOFA and the MAS TFS Regulations, or as informed by the relevant authorities in Singapore.
5.7 In view of system limitations in screening capability, some insurers may not be able to effectively detect designated individuals or entities if they were to perform screening based on a full/exact match logic instead of a partial/fuzzy16 match logic for name searches. A full/exact name match for screening should not be used, as this will likely result in missed sanctions or adverse comments hits. In addition, the screening filters used by the insurer should not be limiting17 and should take into account the various permutations of a person’s first and last names.
5.8 Insurers are reminded that where screening results in a positive hit against the lists mentioned in paragraph 5.1, an insurer shall freeze without delay and without prior notice, the funds or other assets of designated persons and entities that it has control over, so as to comply with applicable laws and regulations in Singapore. This would include both the TSOFA and the MAS TFS Regulations relating to sanctions and freezing of assets of persons. Any such assets shall be reported promptly to the relevant authorities and an STR shall be filed.
5.9 Insurers should also have in place screening procedures when hiring employees, officers18 and agents19, and when establishing business relationships with offshore intermediaries. This should include, where applicable:
(a) background checks with past employers;
(b) credit history checks;
(c) screening against ML/TF information sources; and
(d) bankruptcy searches.