Complying with Anti-Terror Legislation – A Joint Effort!

Clare Lunn

With the all too frequent incidences of appalling terrorist atrocities both in the UK and abroad, there’s never been a time when compliance with sanctions, and terrorist-financing legislation and regulation, has been more important.

Insurers and brokers have an important role to play in providing information that can assist the authorities with counter-terrorism investigations.

Working together

We’re focused on improving controls to counter the threat of terrorism and we’re keen to work with you to manage situations where a customer is either a sanctioned individual or suspected of being involved in terrorist activities.

Insurers and brokers are all subject to the Terrorism Act 2000 and the Proceeds of Crime Act 2002.  In order to comply with anti-terror legislation and regulatory requirements surrounding this area of financial crime, we propose:

  1. A collaborative approach with you, in our response to individuals or organisations who are either identified as being on the sanctions list or suspected of being involved in terrorist-related activity (provided there is no suggestion of collusion with the client or law enforcement instructions not to collaborate)
  2. Whilst “tipping off” is a concern where a SAR is to be or has been submitted about an individual or group of individuals, the Terrorism Act 2000 (S21 F) does make provision for the sharing of information about disclosures between Insurers and brokers, where they have a mutual interest in the client. We’re happy to work with you in the preparation of a SAR and would urge you to contact us immediately if you have concerns about the activities of any of your customers.

More information

Useful information relating to your obligations can be found at:

https://www.gov.uk/government/publications/financial-sanctions-faqs

https://www.handbook.fca.org.uk/handbook/document/FC1_FCA_20150427.pdf

https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets

If you have concerns or would like to know more about our approach to compliance with this anti-terror legislation, please contact Susan.Miller@lv.com.

Additional contact information

General Fraud queries: Matt Crabtree 01489 586434 matthew.crabtree@lv.com

Property and Liability Claims Fraud: Diane Hickman 01689 804587  diane.hickman@lv.com

Motor Claims Fraud: James Garwood 01689 804414 james.garwood@lv.com

Policy Fraud: Anita Bazen 0800 6783012 anita.bazen@lv.com



Categories: Commercial Lines

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