Lloyd's has published a note setting out the minimum standards it expects managing agents to meet in respect of coverholders' compliance with financial crime laws. The guidance includes:
- risk assessment matrices;
- minimum standards for compliance, including an appropriate clause in each binding authority agreement, requiring coverholders to have written anti-financial crime procedures, providing training to coverholders and carrying out appropriate audits;
- a requirement that managing agents understand the sanctions-checking capability of their coverholders and when they carry out sanctions checks;
- checks managing agents should make to ensure their coverholders have written anti-money laundering procedures and suspicious transaction reporting processes; and
- a requirement to ensure coverholders have appropriate anti-bribery procedures in place.