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:
- Registered office of the insured person / insured parties
- Nationality and address of the person applying for the insurance
- 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.