A previous issue of the Update reported that an insurance undertaking had been fined EUR 10 million by the Enforcement Committee of the ACPR for failure with respect to processing of unclaimed life insurance settlements, and that more sanctions were to be expected. On October 31, 2014, another insurer was fined EUR 40 million for similar failures with respect to the backlog of contracts where policyholders died prior to the 2007 legislation, which required insurers to identify and trace beneficiaries in order to pay the amounts due to them. Grounds for sanction included failure to identify deceased policyholders, failure to search for beneficiaries, and failure to set up the list of unsettled contracts. In determining the amount of the fine, the Enforcement Committee took into account the fact that the insurer kept the unsettled amounts and the ensuing damage to beneficiaries, as well as the negative impact on policyholders' trust in life insurance contracts. The Enforcement Committee also took into account the steps taken by the insurer to remedy the failings with respect to the backlog of unclaimed settlements dating back prior to 2007, which should result in the remaining files being settled by December 31, 2015.