AML, CTF &
Anti-Fraud Policy

Vestigo is committed to preventing its services, personnel, systems and relationships from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion, premium diversion, insurance fraud, bribery or other financial crime. Vestigo will not knowingly facilitate unlawful funds, fictitious insurance, false claims, identity misuse or concealment of beneficial ownership.

Insurers are reporting entities for insurer-side obligations under the applicable AML/CFT framework and are responsible for their statutory customer-due-diligence, monitoring and reporting decisions. As a regulated insurance broker, Vestigo supports lawful KYC, identity, authority, beneficial-ownership, sanctions, source-of-funds and fraud-prevention processes; transmits relevant information to insurers; maintains required records; and complies with obligations that apply directly to Vestigo.
Vestigo’s controls do not replace an insurer’s underwriting, KYC, transaction-monitoring, suspicious-transaction reporting or claim-investigation responsibilities. Vestigo will cooperate with the insurer and competent authorities and may apply stricter controls where risk, contract or law requires.

Before or during an insurance transaction, Vestigo may obtain and verify information necessary to establish:

Premiums should be paid only through lawful and authorised channels in accordance with insurer instructions. No client should transfer premium, refund, claim proceeds or other insurance money to a personal account of a director, employee, representative or third party unless the insurer has lawfully authorised the arrangement in writing and it is permitted by regulation.
Vestigo may seek clarification or documents concerning third-party payments, cash, multiple instruments, unusual refunds, changes in beneficiary or bank account, overpayment, rapid cancellation, premium-source inconsistency or payment from an unrelated person. Refund and claim proceeds should ordinarily be directed to the legitimate policyholder, insured, claimant or other person entitled under the policy and law.

Personnel must promptly and confidentially escalate suspicious activity, document irregularity, sanctions concern, premium diversion or fraud through Vestigo’s designated internal channel. They must not warn a person that a matter is under review, that a report may be made, or that an authority or insurer is investigating, where doing so is prohibited or could prejudice the process.

Vestigo may share information with the relevant insurer, reinsurer, bank, service provider, IRDAI, FIU-IND, police, CERT-In, court or other competent authority where required or permitted. Where a statutory report is directly required from Vestigo, it will be made through the prescribed channel. Insurer-side suspicious-transaction reporting remains the insurer’s responsibility where the insurer is the reporting entity.

Vestigo may decline, pause, restrict or terminate an enquiry, transaction or relationship where information is not provided, identity or authority cannot be established, a sanctions or legal prohibition applies, the purpose appears unlawful, the risk is outside Vestigo’s acceptance or capability, or continuing would expose Vestigo, a client, insurer or stakeholder to unacceptable legal, regulatory, ethical or reputational risk. Vestigo may be unable to disclose detailed reasons where confidentiality, reporting or law-enforcement requirements apply.

Relevant personnel will receive risk-appropriate training on KYC, beneficial ownership, sanctions, red flags, premium integrity, claims fraud, cyber-enabled fraud, escalation and confidentiality. Vestigo may monitor compliance through reviews, audit, exception analysis and management reporting and will improve controls based on law, regulation, incidents and emerging risk.

A suspected AML/CFT, sanctions, premium-diversion or insurance-fraud concern may be reported to enquiry@vestigoinsurance.com with the subject “Confidential AML/Fraud Concern”. The report should provide factual details and available documents. Immediate threats or criminal activity may also be reported to the appropriate law-enforcement or emergency authority. Reports made in good faith will be handled in accordance with the Code of Ethics and Speak-Up Policy.