Identity verification for life insurance sold through agents and brokers

What insurers ask of identity checks when they sell through intermediaries

For a life insurer the sales channel and the compliance duty are in different hands. An agent or broker meets the customer, but the insurer carries the policy, and the rules for money-laundering controls fall on the insurer as well. The questions are practical. Who runs the identity check, where does the record live, and what does the insurer hold when a supervisor asks to see it? The steps of the check itself are on the insurance page; this page covers the decision that comes before them.

• Decide, channel by channel, whether the insurer's own session or reliance on an intermediary carries the evidence.
• Run the identity check in the insurer's own scenario when the insurer does not rely on an intermediary's check.
• Let an intermediary start the check without handling the client's documents.
• Keep the session record, the report and the manual decisions in one place.
• Verify other people on the policy, such as a beneficiary, with their own links.

The flow

1. Choose the route. Your own rules decide, for each sales channel, whether the evidence comes from the insurer's own session or from reliance on an intermediary's check. This step sits in your system, not in the platform.
2. Own session. Your backend creates a session through the API and sends the client a one-time link, or the client scans a QR code to move from a desktop to a phone. The agent or broker can start the check without handling the client's documents. The session belongs to the insurer, so it is not reliance.
3. Reliance: eligibility. The insurer may rely on another obliged entity only if that entity applies the customer due diligence and record-keeping requirements of the Regulation, or equivalent ones when it is established in a third country, and its compliance is supervised in a manner consistent with Chapter IV of Directive (EU) 2024/1640. Reliance covers the measures in Article 20(1), points (a), (b) and (c). For an insurance intermediary, Article 2(1), point (6)(c), says when it is a financial institution. If one condition is not met, Article 48 is not available and the insurer uses its own session.
4. Reliance: responsibility. The ultimate responsibility for meeting the customer due diligence requirements stays with the insurer that relies on another obliged entity. The insurer therefore treats the intermediary's statement that a check was done as a claim to be supported by evidence, and not as the evidence.
5. Reliance: evidence retrieval. The conditions for sending information and documents are set out in a written agreement between the insurer and the intermediary. The insurer obtains from the intermediary all the necessary information about the due diligence measures, and takes all necessary steps to ensure that the intermediary provides on request copies of the information collected to identify the customer, the supporting documents used to verify identity, and any information collected on the purpose and intended nature of the business relationship. The information must be provided without delay and in any case within 5 working days. Your rule holds acceptance of the policy until this evidence is in the insurer's hands and has been checked; this step sits in your system, not in the platform.
6. Evidence late, incomplete or not conclusive. The insurer does not accept the policy on the intermediary's check. Your rule sends the client a one-time link for the insurer's own session. Your policy system reads the session status or receives a webhook and issues or holds the policy. Cases that need a person are decided in the dashboard, where the session log, reports and export are kept.
7. Due diligence cannot be completed. The Regulation tells the obliged entity to refrain from establishing the business relationship. For a life insurance contract, where necessary as an alternative to ending the relationship, it tells the obliged entity to refrain from performing transactions for the customer, including payouts to beneficiaries, until due diligence is complied with. A decision to refuse, or a report, is your decision and your process.
8. Intermediary outside the definition. An insurance intermediary that does not collect premiums or amounts intended for the customer and acts under the responsibility of insurers or other intermediaries is excluded from the definition of a financial institution in Article 2(1), point (6)(c). Reliance is then not available on that ground, and the insurer uses its own session. Where such an intermediary only performs tasks for the insurer, Article 18(1) on outsourcing may be the relevant text; it requires the insurer to notify its supervisor before the service provider starts.
9. Other persons. When your process needs another person verified, such as a beneficiary, a separate one-time link is sent to that person.
10. Evidence. For the insurer's own session, the session log, reports and export stay in the dashboard. For reliance, the insurer keeps the copies it retrieved. The Regulation requires a copy of the documents and information obtained in due diligence to be retained for 5 years, counted from the end of the business relationship, the occasional transaction or the refusal, without prejudice to other retention rules.

Where this differs from the insurance page

The insurance page follows the policyholder and then the beneficiary at the payout. This page is about the sale. The new decision is who holds the evidence when an intermediary stands between the insurer and the client: the insurer, through its own session, or the intermediary, through a reliance arrangement. The regulatory frame below shows two texts that deal with that question from different sides.

Modules used

• Document verification, face verification and liveness.
• QR hand-off and one-time links.
• Dashboard for the session log, reports and manual decisions.
• Scenario editor for a scenario per product.
• REST API and webhooks.

Regulatory frame

What two primary texts say about insurers, their intermediaries and the customer information that flows between them. The first eight statements are from the European Union's AML Regulation, which is forthcoming and applies from 10 July 2027. The last four are from the United States rules for insurance companies, Part 1025 of Title 31 of the Code of Federal Regulations.

• Under Article 2(1), point (6)(c), of Regulation (EU) 2024/1624, an insurance intermediary is a financial institution where it acts with respect to life insurance and other investment-related insurance services, except an intermediary that does not collect premiums or amounts intended for the customer and acts under the responsibility of one or more insurance undertakings or intermediaries.
• Under Article 48(1), obliged entities may rely on other obliged entities to meet the customer due diligence requirements in Article 20(1), points (a), (b) and (c), provided that the other entity applies the Regulation's customer due diligence and record-keeping requirements and is supervised, and the ultimate responsibility remains with the obliged entity that relies on another.
• Under Article 49, the relying entity obtains from the entity relied upon all the necessary information about those measures, and ensures that it provides on request copies of the information collected to identify the customer and the supporting documents used to verify identity.
• Under Article 49(3), that information is provided without delay and in any case within 5 working days.
• Under Article 49(2), point (c), and paragraph 4, the entity relied upon also provides any information collected on the purpose and intended nature of the business relationship, and the conditions for the transmission of the information and documents are specified in a written agreement between the obliged entities.
• Under Article 21(1), where an obliged entity is unable to comply with the due diligence requirement, it refrains from establishing a business relationship, and for life insurance contracts, where necessary as an alternative measure to terminating the relationship, it refrains from performing transactions for the customer, including payouts to beneficiaries, until due diligence is complied with.
• Under Article 18(1), obliged entities may outsource tasks resulting from the Regulation to service providers, and notify the supervisor of the outsourcing before the service provider starts to carry out the task.
• Under Article 77, the obliged entity retains a copy of the documents and information obtained in due diligence for 5 years from the end of the business relationship, the date of the occasional transaction or the date of refusal.
• Section 1025.100(b) of Title 31 defines a covered product as a permanent life insurance policy, other than a group life insurance policy, an annuity contract, other than a group annuity contract, or any other insurance product with features of cash value or investment.
• Section 1025.210(a) requires each insurance company to develop and implement a written anti-money laundering program applicable to its covered products, approved by senior management.
• Section 1025.210(b)(1) requires the program's policies, procedures and internal controls to include provisions for integrating the company's insurance agents and insurance brokers into the program and for obtaining all relevant customer-related information necessary for an effective program.
• Section 1025.320(a)(3)(i) makes the insurance company responsible for reporting suspicious transactions conducted through its insurance agents and insurance brokers, and requires it to have policies and procedures to obtain customer-related information from all relevant sources, including those agents and brokers.

This block describes the texts, not our service. For information; not legal advice.

Sources

• Regulation (EU) 2024/1624 of the European Parliament and of the Council, Official Journal text, fetched 26 October 2026.
• Title 31 of the US Code of Federal Regulations, part 1025, rules for insurance companies, electronic Code of Federal Regulations, fetched 27 October 2026.

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