Recital 95

Insurance companies often do not have client relationships with beneficiaries of the insurance policies. However, they should be able to identify cases of higher risk, such as when the proceeds of the policy benefit a politically exposed person. To determine whether this is the case, the insurance policy should include reasonable measures to identify the beneficiary, as if that person were a new client. It should be possible for such measures to be taken at the time of the payout or at the time of the assignment of the policy, but not later.