On April 1, IVASS, the Italian insurance regulator, has published a further letter to the market on dormant policies, an English version of which is attached for your convenience.

Based on the new letter released - which is addressed only to EU companies doing business in Italy under the right of establishment and the freedom to provide services regime - the following incumbents shall need to be carried out by foreign operators:

1. check by 31 December of each year - through the tax revenue IT system - the deaths of the life assureds or of the assureds of accident policies;

2. if the decease is confirmed, the insurance companies must start the liquidation procedure, which includes the search of the beneficiaries not expressly indicated in the policy;

3. by 31 March of the year following the one when the check was made, report to IVASS with respect to the payments made to the beneficiaries.

The check must be carried out for the first time by 31 December 2019.

Breaches to above shall be sanctioned with the application of the sanctions provided by Chapter II of Title XVIII of the Code of Private Insurances, ranging from Euro 30,000.00 (thirty thousand/00) to 10% of the overall company's turnover.