The government of Serbia passed a law on the prevention of money laundering and terrorism financing that came into effect 1 April 2018 (article 128 of the law). The new law requires insurance undertakings engaged in life insurance (excluding nonlife insurance such as accident and health insurance), as well as their agents and brokers to conduct additional due diligence on their clients by requiring additional documents that include:
- Copy of identification card of both the insured and the beneficiary in case of death.
- A certified copy of the passport and registration of residence for foreign citizens.
- Questionnaire for the brokers, the client, the company and any other entity as needed.
- Certified identification cards of the owner(s), a natural person, legal representative and empowered representative of the company.
- Data on the origin of property that is or will be the subject of a business relationship or a transaction.
Additional documentations may be requested by the AML administration when there are reasons to suspect money laundering or terrorism financing in respect of certain transactions or persons. Implementation guidelines have recently been released to add more clarity to the new law. In the absence of a clear list of documents that need to be provided, insurers must rely on compliance officers’ advice to ensure that they have the required documentation to avoid any risk of breaching AML requirements.