Search terms, definitions, and answers about the UAF 2026 Due Diligence Guide
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Set of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. AML frameworks require obligated entities to implement due diligence, monitoring, and reporting mechanisms.
Ref: UAF Guide 2026, Section 1
Process through which the obligated entity identifies, evaluates, and documents its exposure risks to ML/TF/PWMD considering its clients, products, channels, and jurisdictions. Basis for designing proportional controls.
Ref: UAF Guide 2026, Section 4.2
Stock certificates that do not register the owner's name, allowing anonymous transfer. Considered high risk for ML/TF/PWMD. Enhanced DD is required when present in a client's structure.
Ref: UAF Guide 2026, Section 6.1.3.5
Natural person who ultimately owns or controls a client or on whose behalf a transaction is conducted. Includes those who own 20% or more of share capital, exercise effective control through other means, or economically or legally benefit from the operation.
Ref: UAF Guide 2026, Section 5.4
Measures and controls designed to prevent, detect, and disrupt the financing of terrorist activities. Part of the broader AML/CFT framework that obligated entities must implement.
Ref: Law 155-17; UAF Guide 2026
Document establishing ethical principles and behavioral standards that employees and collaborators of the obligated entity must follow regarding ML/TF/PWMD prevention.
Ref: UAF Guide 2026, Section 8
Person designated by the obligated entity to lead and supervise the ML/TF/PWMD prevention program. Must have authority, access to information, and a direct line to senior management.
Ref: UAF Guide 2026, Section 8.2
Set of policies, procedures, controls, and resources implemented by the obligated entity to prevent and detect ML/TF/PWMD. Must be proportional to the entity's size and risk profile.
Ref: UAF Guide 2026, Section 8
National Committee against Money Laundering and Terrorism Financing. Coordinating body for the ML/TF/PWMD prevention system in the Dominican Republic.
Ref: UAF Guide 2026, Section 3
Criterion recognizing as Beneficial Owners natural persons related by marriage, consanguinity, or affinity up to the second degree who, together, meet the 20% threshold or exercise effective control.
Ref: UAF Guide 2026, Section 5.4
Comprehensive and dynamic process of client and transaction identification, verification, analysis, evaluation, and monitoring to manage ML/TF/PWMD risk. Includes four phases: identification, measurement, control, and monitoring.
Ref: UAF Guide 2026, Section 5
Practice of automatically rejecting or terminating business relationships based on a single risk factor (such as being a PEP) without individualized analysis. The 2026 Guide discourages this practice.
Ref: UAF Guide 2026, Section 6.1.3.1
Medium or pathway through which insurance products are marketed. Includes agents, brokers, bancassurance, and digital channels. The channel used is a risk factor in client evaluation.
Ref: UAF Guide 2026, Section 4.3
DD level applicable to high-risk clients. Triggers include: PEPs, third parties/trusts, high-risk jurisdictions, non-face-to-face relationships, companies with bearer shares, and complex structures.
Ref: UAF Guide 2026, Section 6
Intergovernmental organization that sets international standards to combat money laundering and terrorism financing. The 2026 Guide aligns with FATF 2025 standards.
Ref: UAF Guide 2026, Section 1
Country or territory identified by FATF or competent bodies as deficient in ML/TF/PWMD controls. Clients linked to these jurisdictions require Enhanced Due Diligence.
Ref: UAF Guide 2026, Section 6.1.3.2
Level of ML/TF/PWMD risk before applying mitigating controls. Determines the intensity of DD measures required.
Ref: UAF Guide 2026, Section 4.4
Natural or legal person acting as a link between the client and the insurer. Includes agents and brokers. They are independent obligated entities with their own DD responsibilities.
Ref: UAF Guide 2026; Law 146-02
Third and final stage of money laundering where "clean" funds are reintroduced into the legitimate economy. Policy surrenders can be used for this purpose.
Ref: Law 155-17
Initial form or instrument for collecting basic client identification data. Should not be confused with Due Diligence, which is a broader and more comprehensive process.
Ref: UAF Guide 2026, Section 5.8.7
Law against Money Laundering and Terrorism Financing of the Dominican Republic. Main legal framework establishing obligations for obligated entities, typifying crimes, and creating the UAF.
Ref: Law 155-17
Second stage of money laundering where multiple transactions are performed to conceal the origin of funds. In insurance, may include multiple policies, surrenders, and reinvestments.
Ref: Law 155-17
Process of concealing the illicit origin of assets or resources derived from criminal activities to give them the appearance of legality. Comprises the stages of placement, layering, and integration.
Ref: Law 155-17, Art. 3
Money Laundering, Terrorism Financing, and Proliferation of Weapons of Mass Destruction. Term encompassing the three crimes that the prevention system seeks to combat.
Ref: UAF Guide 2026
Person who appears as owner of shares or assets on behalf of another person. Indicator of possible concealment of beneficial owner. Requires identifying the true owner.
Ref: UAF Guide 2026, Section 5.4
Natural or legal person required by law to comply with ML/TF/PWMD prevention regulations. Includes financial institutions, insurance, real estate, notaries, and other specific sectors.
Ref: Law 155-17, Art. 35
Office of Foreign Assets Control. U.S. Department of Treasury agency that administers economic sanctions. Its SDN list is a mandatory reference in DD.
Ref: UAF Guide 2026, Section 5.5
Fourth phase of DD consisting of permanent surveillance of the business relationship to detect changes in risk profile, unusual operations, or red flags.
Ref: UAF Guide 2026, Section 5.9
Person who holds or has held prominent public functions in the country or abroad. Includes 35 specific categories according to Decree 408-17. PEP status extends to family members and close associates.
Ref: UAF Guide 2026, Section 6.1.3.1; Decree 408-17, Art. 19
First stage of money laundering where illicit funds are introduced into the financial system. In insurance, may manifest through payment of high premiums in cash.
Ref: Law 155-17
Person designated to receive the benefit of an insurance policy. According to the 2026 Guide, they are considered Beneficial Owners and must be identified and, in risk cases, verified.
Ref: UAF Guide 2026, Section 5.4
Early cancellation of a life insurance policy with a savings component to recover the accumulated value. Early surrender with significant loss is a money laundering red flag.
Ref: UAF Guide 2026, Red Flags in Insurance
Proliferation of Weapons of Mass Destruction. New addition in the 2026 Guide, expanding the scope from ML/TF to ML/TF/PWMD.
Ref: UAF Guide 2026
Guiding principle establishing that the intensity of DD measures must be proportional to the identified risk level. Allows efficient allocation of resources.
Ref: UAF Guide 2026, Section 4.1
Indicator or circumstance suggesting possible link to ML/TF/PWMD. Does not imply certainty of illicit activity but requires additional analysis and documentation.
Ref: UAF Guide 2026, Section 7
Amount above which a cash transaction automatically triggers a reporting obligation (CTR). In DR: RD$500,000 or equivalent. Does not apply to suspicious operations, which are reported regardless of amount.
Ref: Decree 408-17, Art. 33
Level of risk remaining after applying control and mitigation measures. Must be acceptable to the entity; otherwise, the relationship should be rejected.
Ref: UAF Guide 2026, Section 4.4
Element or characteristic influencing the ML/TF/PWMD risk level. Includes client factors (activity, location, PEP), product factors (complexity, liquidity), and channel factors (in-person, remote).
Ref: UAF Guide 2026, Section 4.3
Tool for classifying clients by risk level combining multiple factors (client, product, channel, jurisdiction). Result: low, medium, or high risk.
Ref: UAF Guide 2026, Section 4.4
Databases of persons and entities subject to restrictions for terrorism, drug trafficking, or other illicit activities. Includes OFAC, UN, EU lists. Must be consulted during DD.
Ref: UAF Guide 2026, Section 5.5
Resolution establishing the procedural regime for administrative sanctions by the Insurance Superintendency against obligated entities (insurers, reinsurers, brokers) for violations of Law 155-17. Defines infractions, sanctioning procedure (investigative and decisional phases), available remedies, and due process guarantees.
Ref: Insurance Superintendency, Resolution 08/2023
DD level applicable to clients classified as low risk. Allows minimum information and extended deadlines. Linked to financial inclusion. Does NOT apply if there is suspicion of ML/TF/PWMD.
Ref: UAF Guide 2026, Section 6
Executive level of the obligated entity with authority to approve high-risk relationships, compliance policies, and escalation decisions. Their involvement is required for PEP clients and high-risk cases.
Ref: UAF Guide 2026, Section 6.1.3.1
Payment method where the total insurance cost is paid in one payment. Due to its nature (high amounts), it can be used for money laundering and requires verification of source of funds.
Ref: UAF Guide 2026, Red Flags in Insurance
Laundering technique consisting of splitting operations into smaller amounts to avoid reporting thresholds or controls. Critical red flag.
Ref: UAF Guide 2026, Red Flags
Activity generating the resources used in a specific operation. Key question: Where do the funds for this operation come from? Always verified, proportional to risk.
Ref: UAF Guide 2026, Section 5.7
General source of the client's assets. Key question: How did they accumulate their total wealth? Verified only in high-risk cases, PEPs, or complex structures.
Ref: UAF Guide 2026, Section 5.7
DD level applicable to medium-risk clients. Includes complete identification, BO verification, relationship purpose, documentation, and risk evaluation.
Ref: UAF Guide 2026, Section 6
Person who lends their name to conceal the true owner or beneficiary of assets, accounts, or transactions. Common money laundering technique. Identifying straw men is a key DD objective.
Ref: UAF Guide 2026, Section 5.4
Mandatory communication to the UAF of cash operations exceeding the established threshold (currently RD$500,000 or its equivalent in foreign currency).
Ref: Law 155-17; Decree 408-17
Communication that obligated entities must send to the UAF when they detect operations that could be linked to ML/TF/PWMD.
Ref: Law 155-17
Regulatory body for the insurance sector in the Dominican Republic. Supervises compliance with ML/TF/PWMD prevention regulations by insurers and intermediaries.
Ref: Law 146-02
Regulation governing the Prevention of Money Laundering and Terrorism Financing for the Insurance Sector, issued by the Superintendency of Insurance. Establishes specific requirements for insurers, reinsurers, and insurance intermediaries regarding DD, reports, and internal controls.
Ref: Superintendency of Insurance of the Dominican Republic
Provision or collection of funds with the intention that they be used to commit terrorist acts or to finance terrorist organizations.
Ref: Law 155-17
Person acting on behalf of another in a transaction. When the relationship is established through third parties, Enhanced DD is required to identify the final client.
Ref: UAF Guide 2026, Section 6.1.3.3
Expected pattern of a client's operations based on their economic activity, income, and relationship purpose. Basis for detecting unusual operations.
Ref: UAF Guide 2026, Section 5.6
Recurring pattern or method used to commit ML/TF/PWMD. In insurance, includes: premium overpricing, early surrenders, use of shell beneficiaries, among others.
Ref: UAF Guide 2026, Annexes
Agency responsible for receiving, requesting, analyzing, and disseminating information related to possible ML/TF/PWMD activities. Issues the Due Diligence Guide.
Ref: Law 155-17
Transaction that deviates from the known client profile or normal market patterns. Not necessarily suspicious, but requires additional analysis.
Ref: UAF Guide 2026, Section 7
Process of confirming the accuracy of information provided by the client through independent sources, official documents, or reliable databases.
Ref: UAF Guide 2026, Section 5.3
3-year period after a PEP ceases functions during which Enhanced DD measures are maintained. Subsequently, enhanced monitoring continues.
Ref: UAF Guide 2026, Section 6.1.3.1
Insurance product combining death protection with value accumulation (savings/investment component). Considered higher ML/TF/PWMD risk due to allowing high premiums, surrender value, and value transfer. Requires DD proportional to amount.
Ref: UAF Guide 2026, Section 4.3
Process of establishing a business relationship with a new client. Key moment to perform initial DD and classify risk level.
Ref: UAF Guide 2026, Section 5.1
Operation that, after analysis, presents indications of connection to ML/TF/PWMD. Generates obligation to file a Suspicious Activity Report (SAR) with the UAF.
Ref: Law 155-17; UAF Guide 2026, Section 7
KYC is an initial form or instrument that collects basic identification data. Due Diligence is a much broader process that includes:
In summary: KYC is the starting point, DD is the entire risk management process.
The 2026 Guide introduces a structured methodology in four phases:
Source of Funds (where does the money for this operation come from?):
Source of Wealth (how did they accumulate their total assets?):
According to Decree 408-17 and the 2026 Guide, mandatory DD applies only to:
However, the 2026 Guide recommends applying proportional controls to other high-value products, such as high-value single premium policies or high-amount property insurance.
Life insurance with savings combines protection and value accumulation, generating characteristics that can be exploited for ML/TF/PWMD:
Required controls:
Ref: UAF Guide 2026, Section 4.3 (Product Risk Factors)
Yes. The 2026 Guide explicitly establishes that "designated beneficiaries in insurance or financial instruments" are considered Beneficial Owners.
This means you must:
Not always, but it requires analysis. These are red flags:
A surrender due to documented economic need, after several years in force, is generally not concerning.
No. The 2026 Guide establishes a clear policy against indiscriminate "de-risking."
What you should do:
Only reject when residual risk is unacceptable, documenting the justification.
Yes. The 2026 Guide is clear: the broker is an obligated entity in their own right, not merely a channel for the insurer.
This means they must:
Yes, if you identify a suspicious operation.
The broker's reporting duty is independent of:
The broker, having direct contact with the client, may detect red flags that the insurer does not perceive.
The broker must maintain for 10 years:
The program must be proportional to your operation, but it must exist. At minimum you need:
Complexity should be proportional to the volume and type of business you handle.
High-risk red flags:
Medium-risk red flags:
It depends on context. These are red flags:
Normal changes (e.g.: due to marriage, birth of children, death of original beneficiary) are not concerning.
Sanctions lists are databases containing persons and entities subject to international sanctions for terrorism, drug trafficking, arms proliferation, or other serious crimes.
Main lists to check:
When to check?
OFAC (Office of Foreign Assets Control) is the U.S. Department of Treasury agency that administers and enforces economic and trade sanctions programs.
Why is it important?
Search tool: sanctionssearch.ofac.treas.gov
If you find a potential match:
Smurfing or structuring is a money laundering technique consisting of splitting large operations into multiple small operations to avoid reporting thresholds or controls.
Characteristics:
In insurance: Can manifest as multiple small policies, fractioned premium payments, or use of several brokers for the same family.
Red flags for structuring in insurance:
Recommended action: Document observations, consult with compliance area, and consider if a SAR is warranted.
Main typologies in the insurance sector:
Law 155-17 against Money Laundering and Terrorism Financing establishes:
Sanctions for non-compliance:
Law 155-17:
Decree 408-17:
UAF Guide 2026:
The three complement each other: the Law establishes the "what," the Decree the "how much," and the Guide the "how."
The Regulation Governing the Prevention of Money Laundering and Terrorism Financing for the Insurance Sector is a specific regulation issued by the Superintendency of Insurance of the Dominican Republic.
Scope:
Main content:
Relationship with other regulations:
Complements Law 155-17, Decree 408-17, and the UAF Guide, adapting general requirements to the particularities of the insurance business. Compliance is mandatory for all entities regulated by the Superintendency.
Resolution 08/2023 establishes the procedural regime for the exercise of sanctioning powers by the Insurance Superintendency under Law 155-17.
Entities covered:
Sanctioning procedure:
Available remedies:
Applicable sanctions: According to articles 74 and following of Law 155-17, including warnings, fines, and license suspension.