Insurance Europe's response to a consultation on the Financial Action Task Force's (FATF) draft risk-based approach (RBA) guidance for the life insurance sector.

Insurance Europe welcomed the FATF's efforts to update the RBA guidance for life insurers, following similar exercises for the banking and money or value transfer serv​ices sectors.

However, Insurance Europe was critical of the inclusion of an annex on non-life insurance. It reiterated the fact that non-life insurance involves a close to non-existent risk of Money Laundering/Terrorism Financing (ML/TF), except through fraud, which is being dealt with by insurers and authorities. Insurance Europe highlighted that this inclusion, as well as the annex on reinsurance, ran counter to the principle underpinning the RBA: that AML/CFT resources should be allocated where they are needed.