Insurance operators should not deal with any person on an anonymous basis or any person using a fictitious name. Prior to establishing an insurance relationship, if an insurance operator has any reasonable grounds to suspect that the assets or funds of a customer are the proceeds of crime or related to the financing of terrorism, the operator should reject the business relationship and, per Article 17 of the AML-CFT Decision, file a suspicious transaction report (“STR”) with the UAE Financial Intelligence Unit (“FIU”).

As per article 13 of the AML-CFT Decision, where an insurance operator is unable to undertake the CDD measures described above, or is a confirmed match to a party included on applicable sanctions lists, the insurance operator must:

In addition, it should add the customer, its beneficial owners, directors, and managers to internal watchlists. The operator should also determine whether the circumstances warrant the filing of a suspicious transaction report (“STR”) or SAR.