ABC Life Co can rely on Top Insurance Brokers Ltd, an insurance intermediary, to carry out which Customer Due Diligence requirements on behalf of the life company?

• A. Identifying a customer.
• B. Verifying the identity of the beneficial owner.
• C. Obtaining information on the purpose of the business relationship with a customer.
• D. Identifying the customer, Verifying the identity of the beneficial owner, and Obtaining information on the purpose of the relationship.

Answer: (D)

Relying on a regulated intermediary to perform customer due diligence tasks is permitted when there’s a formal reliance arrangement and the intermediary is under proper supervision. In CDD, the key steps are identifying the customer, verifying the customer’s identity (and, for corporate customers, identifying the beneficial owners), and obtaining information on the purpose and intended nature of the business relationship. If the life company has a written agreement with Top Insurance Brokers Ltd and the broker is regulated, the broker can carry out these steps on the life company’s behalf. The life company remains ultimately responsible for ensuring CDD is completed and kept up to date, but the actual collection and verification can be performed by the intermediary to meet regulatory requirements efficiently. Therefore, all three aspects—identifying the customer, verifying the identity of the beneficial owner, and obtaining information on the purpose of the relationship—can be carried out by the intermediary.