{"id":13828,"date":"2026-10-13T16:20:17","date_gmt":"2026-10-13T14:20:17","guid":{"rendered":"https:\/\/becobra.be\/amlcos-in-focus-becobra-briefing-exchange-25-09-2026\/"},"modified":"2026-10-14T16:59:24","modified_gmt":"2026-10-14T14:59:24","slug":"amlcos-in-focus-becobra-briefing-exchange-25-09-2026","status":"publish","type":"post","link":"https:\/\/becobra.be\/en\/amlcos-in-focus-becobra-briefing-exchange-25-09-2026\/","title":{"rendered":"AMLCOs in Focus &#8211; Becobra briefing &amp; exchange (25\/09\/2026)"},"content":{"rendered":"\n<p class=\"wp-block-paragraph\">In light of the FSMA&#8217;s announced initiative to assess the knowledge and expertise of Anti-Money Laundering Compliance Officers (AMLCOs) at insurance brokers, Becobra organised an <em>AML Briefing &amp; Exchange<\/em> session on 25 September 2026.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The FSMA&#8217;s initiative follows, among other considerations, findings by the Financial Action Task Force (FATF) concerning the sector&#8217;s knowledge and implementation of anti-money laundering and counter-terrorist financing (AML\/CFT) requirements. Becobra and the FSMA exchanged views on this initiative, including its possible format and scope. These aspects were also discussed during the webinar.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The presentation was delivered by Luc Willems of Caucus Law.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\"><strong>What do we know about the announced assessment?<\/strong><\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Based on the information shared by the FSMA with Becobra and the exchanges during the webinar, the following preliminary outline has emerged:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>Selection and notification: The FSMA is expected to select approximately 50 entities based on its risk assessment model. The selected firms would be notified individually by letter, most likely after All Saints&#8217; Day.<\/li>\n\n\n\n<li>Scope: The assessment would cover both knowledge of the applicable AML\/CFT legal and regulatory framework and its application to practical case studies. According to the preliminary information, no firm-specific questions would be asked.<\/li>\n\n\n\n<li>Reference materials: Participants would be allowed to consult the applicable legislation and their internal procedures. The use of artificial intelligence would not be permitted. The FSMA emphasised that the legislation itself should serve as the primary reference.<\/li>\n\n\n\n<li>Format: A collective assessment of the selected AMLCOs was discussed as one possible approach. It remains unclear whether the exercise will take the form of individual interviews, a written or digital assessment, or another format.<\/li>\n\n\n\n<li>Results and follow-up: The initiative is primarily intended to raise awareness. Any shortcomings identified may lead to feedback and remedial measures. The FSMA&#8217;s usual supervisory approach generally allows firms an opportunity to remedy identified deficiencies before potential administrative sanctions are considered, unless the circumstances warrant a different approach. No details have yet been provided regarding the timing of results or possible individual feedback.<\/li>\n<\/ul>\n\n\n\n<p class=\"wp-block-paragraph\">This information is preliminary. The final arrangements for the assessment had not yet been determined at the time of the briefing. The practical format, permitted reference materials and follow-up arrangements remain subject to official communication from the FSMA.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\"><strong>Purpose of the Becobra briefing<\/strong><\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Against this background, the briefing provided an opportunity to revisit the key AML\/CFT obligations and explore how they translate into the day-to-day operations of insurance brokers.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Drawing on previous FSMA inspections, actual cases and practical examples, the session addressed the risk-based approach, internal AML\/CFT organisation, the identification of atypical transactions and the allocation of responsibilities between insurance brokers and insurers.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Questions and practical experiences shared by participants formed an essential part of the discussion. The proportionality of requirements, preparation for the assessment and outstanding questions regarding its practical organisation were also addressed.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\"><a href=\"https:\/\/becobra.be\/en\/amc-cft-in-practice-becobra-workshop-for-aml-compliance-officers-25-09-2026-presentation-and-exchange\/\" target=\"_blank\" rel=\"noreferrer noopener\">Becobra is making the presentation and a detailed report of the briefing available to the \u00a0members of the TC Legal Affairs &amp; Compliance and the General Assembly<\/a>. The report aims to capture not only the main explanations provided, but also the practical examples, questions raised and nuances emerging from the discussion.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">A recording of the session can also be made available upon request, allowing members to revisit the explanations and exchanges.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\"><strong>Confidentiality and disclaimer<\/strong><\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The presentation, report and, where applicable, recording are intended exclusively for internal use within Becobra member firms. They may not be shared, distributed or published outside the respective organisation.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">These materials are provided for information and practical guidance purposes only. They do not constitute legal advice or an official interpretation by the supervisory authority.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In the event of any inconsistency or difference in interpretation, the applicable laws and regulations, together with the FSMA&#8217;s official positions, guidance and instructions, shall prevail. In addition, individual firms may have specific internal procedures and additional requirements that must also be complied with.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\"><strong>Further follow-up and support<\/strong><\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Becobra will continue to closely follow the FSMA&#8217;s initiative and remains available to assist its members with any further questions, clarifications or support in preparing for the assessment.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">We encourage members who are selected or contacted by the FSMA to inform Becobra accordingly. Information about how the assessment is conducted in practice, the questions asked and any feedback received would also be particularly valuable. Such feedback will enable us to monitor further developments, identify common areas of concern and provide targeted information and support to our members where needed.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>In light of the FSMA&#8217;s announced initiative to assess the knowledge and expertise of Anti-Money Laundering Compliance Officers (AMLCOs) at insurance brokers, Becobra organised an AML Briefing &amp; Exchange session on 25 September 2026. The FSMA&#8217;s initiative follows, among other considerations, findings by the Financial Action Task Force (FATF) concerning the sector&#8217;s knowledge and implementation [&hellip;]<\/p>\n","protected":false},"author":3,"featured_media":13825,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[44,45],"tags":[83,91],"rol":[81],"class_list":["post-13828","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-legal-affairs-and-compliance","category-life-insurance","tag-private","tag-slotje","rol-standaard-lid"],"acf":[],"_links":{"self":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/13828","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/comments?post=13828"}],"version-history":[{"count":2,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/13828\/revisions"}],"predecessor-version":[{"id":13835,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/13828\/revisions\/13835"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/media\/13825"}],"wp:attachment":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/media?parent=13828"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/categories?post=13828"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/tags?post=13828"},{"taxonomy":"rol","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/rol?post=13828"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}