Brokers should not make assumptions about screening new and existing customers and trading partners. Short term deals, wholesaled business and/or introductions that arrive via other regulated firms are not reasons for brokers to avoid screening.
Whilst insurance distribution chains can be complex and involve many outsourced roles, brokers must remember that they cannot outsource their legal and regulatory responsibilities.
Screening is not just about customers. It is important that screening and ongoing surveillance is maintained across all counterparties through which a transaction could contravene a sanction. This includes suppliers, markets, TPAs and producers.