Life insurance company or agent

Recognizing unusual transactions

As a service provider (Life insurance company or agent), you are aware of the practices in your industry. Determining whether a transaction is classified as unusual depends, to a great extent, on your professional opinion. Your opinion corresponds with what is considered unusual within your profession. In addition to your opinion, there are circumstances of an unusual nature which must therefore be reported.


If one of the scenarios described in the general examples below (which are not exhaustive) arises, then this is cause to further examine whether the transaction could be connected with money laundering and/or terrorist financing. If you suspect activities of money laundering or terrorist financing, then you must report it.

Red flags – Life insurance company or agent

  • The insurance contract deviates significantly from what was or could be expected from this policyholder, considering all of the circumstances (based on income, profession, or previously concluded insurance contracts). In other words, the concluded insurance contract is unusual for the policyholder in question
  • The policyholder accepts extremely unfavorable terms and conditions which are not in line with its health or age or that of the beneficiary
  • No (tangible) insured interest can be explained
  • The policyholder concluded multiple sales policies with the service provider and paid for them in cash via an agency or by way of mediation
  • The first premium payment or purchase price payment was made from a foreign bank account