BMA Fines Crown Global Life Insurance $400K

December 31, 2020

The Bermuda Financial Authority has “imposed civil penalties totalling $400,000 on Crown World Life Insurance coverage Ltd. and Crown World Life Insurance coverage [Bermuda] Ltd. [the Companies] pursuant to the provisions of part 20 of the Proceeds of Crime [Anti-Money Laundering & Terrorist Financing Supervision & Enforcement] Act 2008.”

A press release from the BMA stated, “The Authority discovered no proof that the Corporations had been concerned or complicit in any cash laundering or terrorist financing actions. The Corporations at the moment are in compliance with the Proceeds of Crime [Anti-Money Laundering & Anti-Terrorist Financing] Laws 2008 [Regulations].

“The civil penalties have been imposed for the Corporations’ failure to adequately adjust to the next necessities of the Laws:

i] The applying of buyer due diligence measures
ii] Ongoing monitoring of enterprise relationships
iii] The timing of verification
iv] The applying of enhanced due diligence
v] Outsourcing
vi] File-keeping
vii] Anti-Cash Laundering/Anti-Terrorist Financing [AML/ATF] Insurance policies and Procedures
viii] Unbiased audit capabilities
ix] Compliance officer

“The breaches outlined above got here to mild throughout an on-site evaluation of the Corporations’ actions performed by the AML/ATF unit of the Authority in November 2018. The Authority required the Corporations to remediate these failings by 31 July 2019.

“The remediation was not accomplished to the satisfaction of the Authority throughout the timeframe. The Authority views these breaches as severe due to their extent and period, and since they demonstrated a weak point of the Corporations’ inside AML/ATF controls.

“The Laws have been in impact since 2009 and this matter highlights: [1] the significance of licensees having in place up-to-date AML/ATF insurance policies and procedures that are acceptable, efficient, and totally applied with a view to keep away from the chance of monetary merchandise getting used as a automobile for cash laundering or terrorist financing; and [2] the significance of licensees remediating any breaches recognized by the Authority inside cheap timeframes.

“In figuring out the suitable stage of the civil penalties, the Authority decided {that a} penalty of $400,000 was acceptable given the character of the breaches. The Authority additionally took account of the Corporations’ cooperation throughout the on-site and verification course of and the Corporations’ improved processes and procedures for the reason that date of the stated on-site evaluation.

“The Corporations have agreed to proceed to implement enhanced controls going ahead to make sure compliance. These controls signify an enchancment over the earlier controls and had been applied at vital price.”