Services
We provide documentary, analytical, administrative and coordination support across the following areas.
Working in insurance or reinsurance? See how this support applies to the sector.
- Development of AML/CFT policies and risk assessment methodologies.
- Preparation and updating of KYC, CDD and EDD files, including ownership structure analysis and identification of potential UBOs.
- Screening against sanctions lists, PEP databases and adverse media, with results prepared for the client's review.
- Quality review of KYC files and support with complex KYC reviews, including analysis of requests and preparation of documents and explanations.
- Research and preparation of due diligence materials on customers and counterparties.
- Development of internal compliance policies, procedures and checklists.
- Gap assessment of current compliance processes against agreed requirements and the client's internal standards.
- Support with the implementation of changes to compliance processes.
- Analysis of complex compliance cases, including documentation, missing information and risk factors.
- Preparation and implementation support for an agreed improvement plan.
- Commercial and administrative support for contract processes and corporate projects.
- Analysis of commercial terms, obligations and operational implications of contractual documentation.
- Structuring of commercial transaction parameters and preparation of instructions for the client's appointed external adviser.
- Coordination between the client, counterparties and external advisers during the preparation and review of documents.
- Coordination of the client's interaction with licensed providers in relation to company formation, restructuring, closure and other corporate changes.
- Development of governance structures and allocation of authority.
- Preparation of internal management policies, procedures and responsibility matrices.
- Organisation of decision-making and approval processes.
- Development of rules for managing conflicts of interest and corporate information.
- Coordination of internal tasks relating to corporate changes and interaction with external providers.
- Collection and structuring of facts, documents and commercial information relating to claims and disputes.
- Preparation of event chronologies, commercial calculations and lists of disputed issues.
- Preparation of materials for claims and responses to be issued by the client or its appointed external adviser.
- Administrative support for correspondence and settlement processes based on the position determined by the client.
- Administration of documents, deadlines and organisational aspects of arbitration proceedings in coordination with the client's representatives.
Examples of work
Selected anonymised examples of work undertaken by the practice. In every example, all substantive decisions were taken by the client’s authorised personnel.
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Roles across a placement chain
A multi-party insurance placement documented across placement records and correspondence. We mapped the parties and their respective functions and prepared questions to clarify the scope of the review, enabling the client's authorised personnel to confirm which participant was responsible for each remaining step and close the gaps identified.
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Internal policy following a change of instrument
An internal policy referring to a superseded federal framework. We compared the policy with the current instrument and its implementing regulation, identified references and definitions that required updating, and prepared replacement wording, which the client adopted as its updated policy.
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File review and outstanding information
Customer files received with differing levels of supporting information. We reviewed each package against the current internal review standard and prepared a consolidated request covering the outstanding or conflicting information identified, which the client used to bring the files to its current standard.
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Ownership structure and beneficial ownership
A corporate client owned through intermediate legal entities. We traced the ownership and control chain to the ultimate beneficial owner and organised the supporting corporate and identity records, enabling the client to confirm the beneficial owner and finalise the file.
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Review workflow and allocation of responsibility
An internal review process involving business, review and approval roles. We documented the review stages, escalation points and decision states and prepared a proposed allocation of responsibilities, which the client's authorised personnel approved and adopted as its revised process.
Questions to consider
Requirements in this area depend on what a business actually does, not on how it describes itself. The questions below indicate where obligations commonly arise. They are not a determination of your position.
- Do you act as an intermediary in transactions where client funds or assets pass through, or are directed by, your business?
- Do you form, restructure or administer companies, or hold assets, on behalf of clients?
- Do you deal in high-value goods or property, or arrange transactions in them?
- Is your business licensed or supervised by an authority that sets its own AML/CFT expectations?
- Does your written policy reflect how your business operates today, rather than how it operated when the policy was drafted?
- Do you record customer due diligence, including ownership structure and screening results, before a relationship begins?
- Is it clear within your business who decides what happens when something looks unusual, and how that decision is recorded?
If several of these questions are difficult to answer, that is usually where the work starts. Confirming your position requires a review of your actual activities and the requirements that apply to them.
Your matter may require a different scope.
Describe it briefly so that the appropriate next step can be considered.
Submit an enquiryCommon questions
- Do you work with the insurance and reinsurance sector?
- Yes. Our background is predominantly in insurance and reinsurance, including work with brokers and carriers. We understand how these businesses operate commercially, not only what the requirements say.
- What does KYC on a reinsurance counterparty involve?
- Typically: identifying the counterparty and tracing its ownership chain to the ultimate beneficial owners, verifying directors and authorised signatories where relevant, screening against sanctions lists, PEP databases and adverse media, and documenting the risk classification and any enhanced due diligence. The file is prepared for review and decision by your authorised personnel.
- Do you work with MGAs, coverholders and brokers as well as carriers?
- Yes. Files on insurers, reinsurers, cedants, MGAs, coverholders, insurance brokers and reinsurance brokers each raise different questions, such as delegated authority, the position in the placement chain and where the beneficial owners sit. The file is built around the role the counterparty plays.
- Can you help with a KYC backlog or periodic reviews?
- Yes. Where files are incomplete, out of date or due for periodic review, we review them against your own policy, identify missing documents and information, organise updates and prepare refreshed files for your approval.
- Who remains responsible when AML and KYC work is supported externally?
- Your organisation. A licensed financial institution that obtains AML/CFT support from a third party remains responsible for its own obligations, and under the CBUAE framework it is for the institution to assess whether a no-objection from the CBUAE is required. Our support informs your decisions; it does not replace them.
- Do you take over our internal compliance function?
- No. We provide advisory, analytical, administrative and coordination support. Roles that must be held by your own authorised personnel remain with them, and all approvals and regulated decisions are theirs.
- How does an engagement usually begin?
- With a short outline of what you need — either a brief email describing the question or issue, or a short conversation, whichever suits you better. We then set out the scope, the output and the timeline in writing before any work starts, so you know what is included and what is not.
- Can you work alongside our existing advisers?
- Yes. Much of our work involves coordination between a client, its counterparties and its appointed external advisers. Where a matter calls for an authorised specialist, that is arranged in the manner agreed with you.
- We are not sure whether the requirements apply to us. Can you help?
- Yes. Establishing which requirements apply to a particular business, and which do not, is often the first piece of work. The outcome is a clear picture you can act on.
- How do you handle our documents?
- Client information is handled on a need-to-know basis and only within the agreed scope. At the enquiry stage please do not send passports, banking details or client files — we will agree a secure method before any documents change hands.
Discuss your requirements
Send us a short outline of what you need and we will come back to you.
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