AML/CFT COMPLIANCE A KEY FOCUS OF RECENT SUPERVISORY INSPECTIONS BY THE HONG KONG INSURANCE AUTHORITY

Late last week, the Hong Kong Insurance Authority (IA) published a circular setting out its key findings from anti-money laundering and counter-financing of terrorism (AML/CFT) onsite inspections of authorised insurers carrying on long term business.

The IA conducted visits of more than 20 insurers to review their AML/CFT policies, procedures and controls and their compliance with the relevant legislative and regulatory requirements. Continue reading

EXTENDING THE SENIOR MANAGERS AND CERTIFICATION REGIME TO INSURERS

The UK Senior Managers and Certification Regime (SMCR) is being extended to all financial services firms during 2018. PRA and FCA proposals applying to insurers build on the Senior Insurance Managers Regime (SIMR) although the transition to the SMCR is complicated by overlapping Solvency II requirements.

We have prepared a guide for insurers to the proposals set out in PRA CP14/7 and FCA CP17/26 (please click here for a copy).

Our experience of working with clients on the SMCR and the SIMR suggests that implementation projects should begin now rather than waiting for the outcome of the consultations.

FCA CONSULTS ON EXTENDING THE SMCR TO INSURANCE INTERMEDIARIES

The FCA has published proposals to extend the Senior Managers and Certification Regime (SMCR), which already applies to banks, to other financial services firms.  The new rules, which are designed to make individuals more accountable for their actions, will affect insurance intermediaries and their employees.

We have prepared:

  • a two page “at a glance” guide (click here) to the FCA’s proposals; and
  • a more detailed briefing (click here) which considers the implications for insurance intermediaries and their employees of the FCA’s proposals.

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PRA consults on amendments to the Senior Insurance Managers Regime (SIMR)

The PRA has published a consultation paper (CP8/17), which includes proposed amendments and optimisations to the Senior Insurance Managers Regime (SIMR).  It also includes a proposal to strengthen governance through requiring insurers to take steps to encourage board diversity.  This CP is relevant to all Solvency II insurance firms (i.e. UK Solvency II firms, the Society of Lloyd’s and Lloyd’s managing agents, and third country (re)insurance branches), and to large non-Directive firms (large NDFs).

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A new regime for senior insurance managers: changes to the approved persons regime for Solvency II firms

In November 2014, the PRA and the FCA proposed wide-ranging reforms of the Approved Persons Regime (APR) for insurers and reinsurers.

The PRA will introduce a Senior Insurance Managers Regime (SIMR), in line with its commitment to extend to insurers changes being made for banks. Outrage expressed about a lack of individual accountability has been more muted in the case of insurers than for banks. The underlying driver for change is, however, the same. It is considered unacceptable for senior managers within financial institutions to shirk responsibility when those institutions fail. The fast-approaching Solvency II start date was a further reason for the PRA and the FCA (together, the Regulators) to look again at the APR. Continue reading