(1) Location Proximity
• Application for a policy from a potential client in a distance place where a comparable policy could be provided “closer to home”.
• Introduction by an agent/intermediary in an unregulated or loosely regulated jurisdiction or where organized criminal activities (e.g. drug trafficking or terrorist activity) or corruption are prevalent.
• The applicant for insurance business use a mailing address outside the insurance supervisor’s jurisdiction and where during the verification process it is discovered that the home telephone has been disconnected.
(2) Doccument
• Any want of information or delay in the provision of information to enable verification to be completed.
• The applicant for insurance business is reluctant to provide normal information when applying for a policy, providing minimal or fictitious information or, provides information that is difficult or expensive for the institution to verify.
(3) Premium Payment
• An atypical incidence of pre-payment of insurance premiums.
• Attempts to use a third party cheque to make a proposed purchase of a policy
• The applicant for insurance business attempts to use cash to complete a proposed transaction when this type of business transaction would normally be handled by cheques or other payment instruments.
• The applicant for insurance business requests to make a lump sum payment by a wire transfer or with foreign currency.
(4) Doccument
• The client accepts very unfavorable conditions unrelated to his or her health oe age.
• The client requests an insurance product that has no discernible purpose and is reluctant to divulge the reason for the investment.
• Insurance policies with values that appear to be inconsistent with the client’s insurance needs.
• A transfer of the benefit of a product to an apparently unrelated third party.
• A change of the designated beneficiaries (especially if this can be achieved without knowledge or consent of the insurer and/or the right to payment could be transferred simply by signing an endorsement on the policy.)
• Substitution, during the life of an insurance contance, of the ultimate beneficiary without any apparent connection with the policyholder.
• Request for a large purchase of a lump sum contract where the policyholder has usually made small, regular payments.
(5) Policy Surrender
• The applicant for insurance business establishes a large insurance policy and within a short time period cancels the policy, requests the return of the cash value payable to a third party.
• The applicant for insurance business shown no concern for the performance of the policy but much interest in the early cancellation of the contract.
• Early termination of a product, especially at a loss, or where cash was tendered and/or the refund cheque is to a third party.
(6) Other Cases
• Application for business outside the policyholder’s normal pattern of business.
• The transaction involves use and payment of a performance bond resulting in a cross border payment (wire transfers) = the first (or single) premium is paid from a bank account outside the country.
• Large fund flows through non-resident accounts with brokerage firms.
• Insurance policies with premiums that client’s apparent means.
• Any transaction involving an undisclosed party.
• The applicant for insurance business appears to have policies with several institutions
• The applicant for insurance business wants to borrow the maximum cash value of a single premium policy, soon after paying for the policy.