Comprehensive analysis of the Financial Analysis Unit regulatory update and its impact on the Dominican insurance sector.
An analysis presented by
The UAF 2026 Due Diligence Guide represents a substantial evolution from the 2020 version. From being a basic guidance document, it has become a comprehensive technical tool that harmonizes criteria and reduces interpretive asymmetries across sectors.
The new guide not only explains what due diligence is, but provides a clear methodology and practical cases to implement it effectively in each sector.
The most significant changes between both versions
Although mandatory DD is limited to life insurance and investment products, the new guide recommends proportionate controls for all products according to their risk exposure.
Policy beneficiaries are now explicitly considered "beneficial owners", requiring identification and verification according to risk level.
DD is no longer just the Compliance Officer's duty. Underwriting, claims, and sales staff are now the first line of defense.
New crucial technical distinction: source of funds for each premium, source of wealth only for high risk and PEPs.
PEPs should not be automatically rejected. The guide requires objective criteria, documented analysis, and reasonable mitigants.
Life and investment insurance are long-term relationships. They require periodic updates, especially for beneficiary changes.
Detailed DD documentation, risk analysis, decisions, and communications must be retained for a minimum of 10 years.
Brokers are independent obligated subjects with their own responsibilities, not mere channels for insurers.
Must implement policies, procedures, designate a compliance officer, and train staff. Cannot rely exclusively on the insurer.
The broker has direct contact with the client. They are the first to detect alert signs such as disproportionate premiums or unusual beneficiaries.
When suspicious operations are identified, they must report directly to the UAF, regardless of whether the insurer accepts or rejects the policy.
Must maintain their own files with KYC forms, coherence analysis, and alert records. Retain for 10 years.
Situations requiring additional scrutiny according to the new guide
Premiums that significantly exceed the client's declared economic capacity.
Request for total surrender shortly after purchase, accepting significant losses.
Designation of beneficiaries residing in countries with low international cooperation.
Recurring changes of beneficiaries without clear justification or to unrelated persons.
Premiums paid by persons other than the policyholder without clear relationship or justification.
Client who shows no interest in insurance coverage, only in the surrender value.
Comprehensive documents that delve into the guide changes and their impact on the insurance sector
Detailed study of all changes between the original guide and the 2026 update. Includes new concepts, 4-phase methodology, PEP treatment, and more.
Specialized analysis for insurers and insurance brokers. Includes specific obligations, alert signs, practical cases, and implementation recommendations.
Complete vocabulary of guide terms and specialized FAQ for the insurance sector. Includes search with flexible matching.
Two training programs: Update for experienced professionals and comprehensive training from fundamentals. 2 and 4-hour formats.
Experience our interactive platform with real restrictive list queries (OFAC, UN, EU) and guided Due Diligence forms.
Consult the complete document published by the Financial Analysis Unit
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