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Lloyd’s Issues Guidance on Compliance with Brazilian Anti-Money Laundering Regulations

London, [Date]

Lloyd’s has issued a market bulletin to provide guidance to its managing agents and cedants on compliance with Brazilian anti-money laundering (AML) regulations.

Compliance Requirements

The bulletin outlines the requirements for managing agents and cedants to identify and verify the Politically Exposed Persons (PEPs) associated with their clients, particularly those in the reinsurance sector. The guidelines aim to ensure that Lloyd’s market participants comply with the Brazilian AML framework, which is overseen by the Superintendência de Seguros Privados (SUSEP).

• Identifying PEPs: Managing agents and cedants are required to identify PEPs at the outset of a relationship and obtain senior management approval.
• Ongoing Monitoring: The guidelines emphasize that ongoing monitoring is essential to ensure compliance with AML regulations. Managing agents are advised to update their internal procedures to allow for regular AML monitoring of Brazilian PEP business and to maintain accurate records of PEP assessments.

Lloyd’s Brazil Audit

Lloyd’s Brazil will conduct an annual audit to ensure that its managing agents have adequate AML controls in place, including processes for identifying and verifying PEPs. The bulletin also provides guidance on the definition of a PEP and lists the types of public officials who are considered PEPs under Brazilian law.

Definition of a Politically Exposed Person (PEP)

A PEP is an individual who is considered to pose a higher risk for potential involvement in financial crime, particularly with regard to money laundering and bribery and corruption, due to the influence their position may hold. According to SUSEP circular 445/12, a PEP includes public agents who hold or have held in the past five years positions, offices, relevant public duties, as well as their representatives, family members, and other persons of their close relation, in Brazil or in foreign countries, territories, and facilities.

Contact Information

For further information or clarification on these guidelines, managing agents should contact Lloyd’s International Trading Advice at +44 (0)20 7327 6600 or email [email address].

Source: Lloyd’s Market Bulletin, [Date]