Insurance Companies and Insurance Brokers

The Financial Transactions Reporting Act applies to all insurance companies and insurance brokers in Fiji. Your key obligations under this Act are as follows:

1. Identify and verify your customers (policy holders) and beneficiaries of life insurance or investment linked insurance policies;
2. Monitor your customers transactions;
3. Maintain proper customers records;
4. Report transactions to the Financial Intelligence Unit;
5. Implement appropriate internal controls and systems to protect your organisation from being used for money laundering and terrorist financing purposes.

Customer Identification and Verification
You must undertake specific procedures to identify customers (policy holders) and beneficiaries of life insurance or investment linked insurance policies. You must also ensure that insurance policies are opened and maintained in the true name of a customer (policy holder). Holders of non-investment type insurance policies or general insurance policies are exempted from these customer identification requirements.

For further guidelines refer to:

• Policy Advisory 1/2007- Customer Due Diligence of Existing Customers’ Accounts
• Policy Advisory 2/2007- Customer Due Diligence of Customers Who Have     Insufficient or No Official Identification Documents
• Policy Advisory 3/2007- Identification and Verification of a Customer’s Signature
• Policy Advisory 4/2007- Identification and Verification of Occasional Transactions
• Policy Advisory 1/2008- Identification and Verification of Customers of Insurance Providers
• Policy Advisory 2/2008- Identification and Verification of Clients and Beneficiaries of Employer Funded Group Life Insurance Policies
• Policy Advisory 1/2010 - Identification and Verification of a Customer's Signature
• Policy Advisory 2/2010 - Use of Referee Letter to Verify a Customer's Identity
• Guideline 4 of 20 August 2009 - Customer Identification & Verification

Monitor your Customers transactions;
You must scrutinize or monitor your customer’s transactions to ensure that the transactions being conducted are consistent with your knowledge of the customer and his or her background.
For further guidelines refer to: 
Guideline 1 of 26 October 2007 – Suspicious Transactions

Maintain proper Customers records
You must establish and maintain records of your customers’ identity, transactions and records of all reports of transactions made to the FIU. Any enquiries made to your institution by the FIU and other law enforcement agency must also be recorded.
For further guidelines refer to:  Policy Advisory 7/2007- Record Keeping

Report transactions to the Financial Intelligence Unit

You must report the following types of transactions to the FIU:

• All cash transactions of $10,000 or more including equivalent amounts in foreign currency. “Cash” includes currency, bank drafts, bank cheques, bearer bonds, traveler’s cheques, postal notes and money orders.

Exemptions apply to certain types of cash transactions. For guidelines on exemptions to cash transaction reporting refer to: Policy Advisory 6/2007- Application of Exemption Provisions for Reporting of Cash   Transactions

• All suspicious transactions including transactions or attempted transactions for which satisfactory evidence of identity was not obtained from the customer.

Terrorist Property
If you have in your possession or your control any property which is owned or is controlled by a terrorist or terrorist group or if you have information on a transaction or proposed transaction relating to a terrorist property, you must report this information to the FIU.

For further guidelines refer to:
Guideline 2 of 26 October 2007 - Reporting a Suspicious Transaction by Paper
Guideline 3 of 22 May 2009 - Reporting Cash Transactions of $10,000 or above by Paper

Internal controls and systems
Other measures that your financial institution must implement are:

• Develop and implement internal policies and procedures to comply with the FTR Act.
• Appoint a “Compliance Officer” to be responsible for ensuring compliance with the FTR Act and Regulations.
• Regularly review your compliance with your internal anti money laundering and terrorist financing polices and procedures.
• Implement adequate recruitment procedures to screen potential employees.
• Have regular training for staff on anti-money laundering and terrorist financing issues and legislative requirements.