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The latest thinking and expert insights into the insurance industry.
27 September 2017
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Our Customers Are Obviously Not Terrorists. Right?

Tom van der Lek is product manager UBO & Compliance at FRISS. He advocates the use of automated processes to search databases and lists for known fraudsters, money launderers or even terrorists so that they cannot take advantage of insurance companies.

money-launderingNo financial organization wants to consciously or deliberately cooperate in money laundering practices or even terrorism, and that certainly applies to insurance companies. For insurance applications and claims, it is necessary to check whether someone appears on international sanctions lists or on the PEP (Politically Exposed Persons) list.

The European Union has a list of 17,003 names of persons, organizations and countries with whom no business can be done. Many countries also publish their own sanctions list: the Dutch terrorist list contains 124 names, the Belgian list 251 and the United Kingdom list 9,308.

Unfortunately, new names are added to the sanctions lists after each terrorist attack or dismantled network. The PEP list is directly affected by political appointments and dismissals. Someone who sailed through screening effortlessly a year ago, may cause alarm bells to ring today. It is therefore important to keep the screenings as current as possible.

Many insurance companies carry out a periodic check every two or three months. This has two disadvantages: it generates a large number of hits all at one time, all of which need to be checked, and the following day you are already one step behind.

Within this framework, Continuous Compliance has been created: an organization’s complete relationship database is checked daily against the most current lists.

Daily check

check-on-terroristsAt FRISS, we check the databases of our customers every day based on the current lists that we generally retrieved on the same day from the issuing institutions, often governmental organizations. The daily check allows for the processing of compliance matches for our customers to be performed in small weekly batches. But the most important thing is that these insurance companies have the certainty that they are not facilitating unwanted criminal activities.

We perform this check for business insurances as well. For this, we screen all directors in order to determine the Ultimate Beneficial Owner (UBO). It is important to know precisely who is behind a business that wants to conclude insurance. The direct owner may have a clean slate, but what about the holding, sister companies or big investors?

Ultimately, it is incredibly important for all companies, but certainly for insurers, to have the best possible information on those with whom you do business. Check, check and continue to check!

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1. Introduction

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1.1.  Controller

The controller of the processing of personal data is:

FRISS Fraudebestrijding B.V.
Orteliuslaan 15
3528 BA
Utrecht

This processing of personal data is registered with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) in The Hague under reporting number m00004997.

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In addition to the personal data you provide to FRISS yourself, FRISS may collect, record and process additional (personal) data if you use the (web) services of FRISS. This concerns the following personal data:

  • data from the used equipment, such as a unique device ID, version of the operating system and settings of the device you use to access a service;
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1.3.  Provision of (personal) data to third parties

Your (personal) data will never be provided to third parties without your permission, unless we have an obligation to do so pursuant to legislation or regulations or you have given permission for this.

1.4.  Security of data

FRISS respects your privacy and ensures that personal data are handled confidentially and with the utmost care. All processed (personal) data is stored exclusively in secure databases. These databases are only accessible to employees of FRISS, to the extent that this access is required by virtue of their position. FRISS makes every effort to secure these systems against loss and/or any form of unlawful use or processing.

1.5.  Inspection, correction and deletion of data and the right to object

You can view your data that is processed by FRISS at any time and free of charge and, if you so wish, modify this data or have it deleted. You can also object to receiving information about products, services or content of FRISS. If you wish to make use of one of these options, you can send an e-mail to the Data Protection Officer of FRISS via privacy@friss.eu or write to the following address:

FRISS | fraud, risk & compliance
Attn. Data Protection Officer
Orteliuslaan 15
3528 BA Utrecht.

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When using this website, information about your use of these services and other websites may be collected by or on behalf of FRISS, for example by means of cookies.

A cookie is a small file that is sent along with pages of a website and stored by your browser on the hard disk of your computer. We use cookies to remember settings and preferences. You can disable these cookies via your browser.

2.1.  The purposes for which FRISS uses cookies

On our website we use cookies for the following purposes:

  • for statistical purposes, in order to analyse the use of FRISS websites. This allows us to keep track of the number of visitors and see which parts of our website are popular. We use Google Analytics in order to track and consult these statistics. On this website you can find explanations about all cookies that may be placed by Google;
  • for what is known as ‘targeting’ purposes, if you have used the download form. By targeting we mean building a profile of you based on your surfing behaviour on our website, after which we may contact you by telephone or e-mail based on the interests you have shown in order to offer you FRISS services that you may be interested in. We use HubSpot in order to track and consult these statistics. On this website you can find explanations about all cookies that may be placed by HubSpot;

3. Changes to this Cookie and Privacy Statement

FRISS may make changes to this Cookie and Privacy Statement. All modifications will be published on this page. We advise you to consult this Cookie and Privacy Statement regularly, so that you are always aware of the content of the current Cookie and Privacy Statement.

 

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