The National Insurance Council (CNA) has implemented a risk guide to combat ill-gotten gains and money laundering attempts.
The guide covers a range of matters from strict customer identification and enhanced monitoring of financial flows to increased oversight of life insurance and severe penalties for violations. The intended goal is to disrupt the channels used to launder funds of dubious origin.
Customer identification requirement
In certain situations, insurance companies will have to "precisely identify the sources of their clients' funds and ensure continuous monitoring of transactions carried out throughout the contractual relationship".
The text emphasises the need to "verify the consistency" between the transactions carried out, the client's profile, their professional activity, and their risk level. The documents, information, and data collected "must be regularly updated, particularly for clients classified as high risk".
The guide explicitly places life insurance in the category of high-risk products. Therefore, companies will be required to identify the beneficial owner, to verify their identity when benefits are paid, to include the beneficial owner in the overall risk assessment, and to apply enhanced due diligence measures as soon as the risk level increases.
Insurers must, before entering into any contractual relationship or occasional transaction, fully identify clients, agents, and beneficial owners based on reliable and independent documentation. For individuals, the required information includes, in particular, full name and nationality, date and place of birth, current address andemployment status, the nature and purpose of the contractual relationship, and data relating to assets and income, as well as the source of funds when necessary. For legal entities, companies must collect detailed information on the legal structure, shareholding, directors, and control organisation to identify the beneficial owner.
The text formally prohibits the opening or maintenance of anonymous or fictitious accounts and mandates the immediate termination of the contractual relationship when due diligence obligations cannot be met.
Politically exposed persons classified as high risk
One of the most sensitive measures in the guide concerns politically exposed persons. Political figures, their families, and close associates are now included among high-risk clients.
Any contractual relationship with this category requires prior authorisation from senior management, thorough verification of the source of funds and assets, and continuous and enhanced monitoring throughout the relationship.
In cases of suspected money laundering or terrorist financing, insurance companies are required to refuse to open or continue the contractual relationship, to immediately freeze or seize the funds in question, and to report suspicious transactions without delay to the financial intelligence unit. The legislation also specifies the obligation to apply national and international sanctions lists and to regularly update customer information.
The guide also reiterates the strict prohibition of cryptocurrencies in Algeria, with any use punishable by imprisonment and fines.
The document provides a detailed list of behaviours that may indicate money laundering attempts, including changing the beneficiary at the time of payment, unjustified use of large cash payments, taking out multiple contracts with different companies, inconsistencies between the client's financial situation and the insured amounts, requests for early redemption or cancellation without economic justification, and refusal to provide information on the origin of funds.