Sanctions Compliance - Important notice from the Italian Insurance Supervisory Authority to remind key obligations for insurance companies (including Italian branches of foreign companies/intermediaries).
a) All entities must implement policies and procedures to detect funds and economic resources subject to asset freeze.
b) All entities are prohibited from engaging in business with sanctioned entities/persons, unless under an authorization from the Financial Security Committee.
c) Companies operating in non-life business must as well comply with EU restrictive measures, but they are not subject to an obligation to report freezing measures to the Financial Intelligence Unit (this reporting obligation is only for entities subject to AML obligations).
d) However, as far as Russia sanctions are concerned, insurance companies, including those operating in non-life business, must comply with reporting obligations under article 8 of Regulation (UE) no 269/2014.
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