Guide · Insurance brokers
Do non-life insurance brokers need AML checks?
Insurance intermediaries are not one uniform category under EU anti-money-laundering law. The obligation attaches to life and investment-linked products specifically, not to insurance brokerage in general. This guide draws the line precisely, covers what happens with a mixed book, and flags what changes under the incoming EU regulation.
- AML rules apply only to life and investment-linked insurance intermediation
- Non-life products, motor, home, liability, sit outside AML scope entirely
- A mixed book means AML checks only for the in-scope product line
Why are some insurance brokers AML-obliged and others not?
EU anti-money-laundering law targets financial products that can carry or accumulate value in a way that makes them useful for moving illicit funds, and most non-life insurance, motor, home, travel, liability, simply does not work that way: a claim pays out against a loss, and there is no investment or cash-value component to launder through. Life insurance and investment-linked insurance products are different, since they can hold and transfer value much like an investment account. The EU directive framework therefore obliges insurance intermediaries specifically when they act in relation to life or other investment-related insurance services, not insurance intermediation as a whole.
What counts as a 'life or investment-linked' product for this purpose?
This covers life insurance policies and investment-linked or unit-linked products where the policy holds or accumulates a cash value tied to underlying investments, rather than a pure protection product with no savings or investment element. A term life policy that only pays out on death, with no surrender value, sits closer to the protection end of the spectrum, while a whole-of-life or unit-linked policy with a cash or investment component sits squarely in scope. Where a product mixes protection with an investment element, treat it as in scope rather than assuming it out, and confirm the classification with your insurer or your national supervisory body if it is not obvious from the policy terms.
If you only broker car, home or liability insurance, are you out of scope entirely?
Yes, on the current EU framework. If your entire book is motor, home, travel, liability or other non-life products, with no life or investment-linked policies at all, insurance intermediation of that kind falls outside the AML obliged-entity list. That does not remove other duties you may have: GDPR obligations around the personal and vehicle or property data you collect are unaffected, and some countries add insurance-specific rules beyond the EU AML baseline, so this is an AML-specific answer, not a full compliance picture.
What happens if your book is mixed, some life, some non-life?
The obligation follows the product line, not the broker as a whole. A broker who sells both motor insurance and life or investment-linked policies is an obliged entity for the life and investment-linked business, and can run that book without AML due diligence duties for the pure non-life business. In practice this usually means routing new clients differently depending on which product they are buying: a straightforward car insurance quote proceeds without a due-diligence step, while a life or investment-linked application goes through identification and, where relevant, beneficial-owner checks first.
What does the incoming EU AMLR change for insurance intermediaries?
Regulation (EU) 2024/1624, the new EU Anti-Money Laundering Regulation known as the AMLR, continues to scope insurance intermediaries in only where they act in relation to life or other investment-related insurance services, keeping the life versus non-life distinction rather than widening it to intermediation in general. The AMLR applies directly across all member states without needing national transposition, while the accompanying directive, AMLD6, Directive (EU) 2024/1640, covering supervisory and institutional matters, has a national transposition deadline of 10 July 2027. For a broker whose book is already correctly scoped today, this is continuity rather than a new duty to plan for.
How a broker who is in scope builds the check into client intake
The practical approach is a routing step early in client intake: ask which product the client is buying, or infer it from which quote they requested, and send only the life or investment-linked path through identity verification, screening and any beneficial-owner check, while the non-life path proceeds straight to the policy documents and signature. This keeps AML checks proportionate to the part of the book that actually needs them, instead of running an identity and screening step on every car insurance customer regardless of product.
In Braigest
Route only the life-linked product line through AML screening
A decision step in a Braigest workflow can send life and investment-linked applications through identity and AML screening while the non-life path skips straight to signing. Workflow building is included from the Solo plan at €29/month.
Frequently asked questions
Does home or motor insurance ever need AML checks?
Under the current EU framework, no. AML obligations for insurance intermediaries attach to life and investment-linked products, not to non-life products like motor, home, travel or liability insurance.
What if a policy has a small savings component alongside protection?
Treat a policy with any investment or cash-value element as in scope rather than assuming it is out. Confirm the classification with your insurer or your national supervisory body if the policy terms are not clear.
Will the new EU AML Regulation change this for non-life brokers?
No. Regulation (EU) 2024/1624 keeps the same life and investment-linked scope for insurance intermediaries. Non-life intermediation stays outside AML obligations under the new rules.
Do I need separate software for the life and non-life parts of my book?
No. A single client-intake flow can route applications differently by product, sending only the life or investment-linked path through identity and screening steps.
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