With the Sanctions Act Protocol the VNAB aims to have in place a basic division of tasks between insurers and brokers as to conducting the customer due diligence reviews (CDD checks), the transaction due diligence reviews (TDD checks) and the payment due diligence reviews (in case of payment to third parties) with respect to:
- The policyholder
- The (named) insured parties
- The ultimate beneficial owner (UBO)
The beneficiary/beneficiaries These data are checked against the sanction lists by the Sanctionpl@tform. The protocol applies to VNAB members and policies and claims recorded by means of the e-ABS application. VNAB members conform to the division of tasks set out in the protocol as basic division of tasks to run the CCD and TDD checks. All VNAB members have access to the Sanctionpl@tform. Where required, market players can decide in consultation to run additional checks to the actions described in the protocol.
Whether a party presents a risk, will, among other things, depend on:
1. Business location of the policyholder/insured
2. Nationality and address of the party submitting the insurance proposal
3. Nationality and address of the board members and any other party involved such as lawyers and intermediaries.
Should the business location or nationality be linked to a country subject to sanctions, this constitutes an increased risk. The VNAB emphasises that compliance with statutory obligations is each party’s own responsibility.