DUE DILIGENCE

Introduction

Part of the process of knowing and identifying customers includes due diligence, a requirement imposed by regulatory institutions under which StateTrust Life & Annuities operates.

There are several types of due diligence:

• Knowing your client
• Strengthening the background check process
• Identifying customers
• Understanding each customer’s business, professional and family traits.
• Crosschecking customer with other governments or military forces.

Client Knowledge

The process of identifying various aspects of a customer includes collecting information about:

• Their personal background
• Source of their estate
• Their work/professional activities
• Personal and professional references

StateTrust Life & Annuities’ agents and sales representative have the business responsibility of uncovering information about our customers, as part of our company’s efforts to comply with guidelines dictated by anti-money laundering laws.

During the process of establishing a policy or plan, StateTrust Life & Annuities’ New Business department implements the following procedures:

• Background Check
• Interview with plan/policyholder when the annual policy or plan exceeds a specific amount in U.S. Dollars or other currencies.
• Double-checking customers’ personal information.
• Review by private investigators when policies or plans exceed a specific limit in Dollars or Euros, as established during the registration process.

Background Check Process 

At StateTrust Group and its companies, we implement all standard procedures to obtain relevant information about our customers. Furthermore, we implement a series of additional measures, raising the bar to ensure a thorough and demanding due diligence process.

To that end, we have designed forms and procedures to verify the information we receive, through our Client Review Program, which is based on:

• Information about source of assets from customers identified as high risk.
• Research to verify the source of the estate, and whether there are specific red flags due to inconsistencies or negative information.
• Visiting prospects at their residence and/or workplace.
• Record review of all visits to ensure customers meet all requirements.
• Verification of customer’s identity based on regulations set forth by the Compliance Department.
• All names associated with the customer are reviewed to ensure they have been checked against the OFAC database (and other similar lists), including periodic updates.
• All names associated with the customer are also reviewed by World Compliance, OFAC, the most current, updated list of politically exposed persons, and other global databases.
• Agents and brokers are required to follow all requirements established by the Compliance Department regarding knowing customers and the source of their estate. If necessary, documents supporting this information should be attached to the customer’s file.

Customer Identification Program

The Customer Identification Program contains all the documentation needed to issue a policy or plan, the forms and applications that customers must complete, and the required forms of identification they must present (citizenship ID document, passport, and financial and medical information).

StateTrust Life & Annuities consults with agents, international representatives, and managers in order to implement updates or make decisions about canceling, approving or rejecting a relationship with a customer.