Dutch Insurance Exchange Association

Sanctions Act Protocol

With the Sanctions Act Protocol, the VNAB wants to achieve a basic division of tasks between insurers and brokers for performing customer due diligence (CDD checks), payment to third parties and risk assessment (TDD checks) regarding:

  • The policyholder
  • The (named) insured parties
  • The ultimate beneficial owner (UBO)
  • Benefit recipient(s)

These data are checked against the sanctions list by the Sanctiepl@tform.

The protocol applies to the VNAB members and the policies and claims that are administered through the e-ABS application. They conform to the division of labor described below as a basic division of labor for performing the CCD and TDD checks. All VNAB members can use the Sanctiepl@tform. Market parties may, in mutual consultation, carry out additional checks on the actions described in the protocol.

Whether a party poses a risk will depend, among other things, on:

  1. Registered office of the insured person / insured parties 
  2. Nationality and address of the person applying for the insurance 
  3. Nationality and address of the management and any other parties involved such as lawyers and mediators.

If the place of residence or nationality is linked to a sanctioned country, this entails an increased risk. The VNAB emphasizes that everyone has their own responsibility for complying with legal obligations.

All other documentation can be found here