On 5 October 2026, the FSMA published a report on its inspections concerning anti-money laundering and countering the financing of terrorism (AML\/CFT).<\/p>\n\n\n\n
Although the inspections specifically targeted banking and investment services brokers, the findings also provide valuable insights for insurance intermediaries subject to AML\/CFT legislation. The report sheds light on the areas examined by the FSMA and its expectations regarding the organisation and effective implementation of AML\/CFT frameworks.<\/p>\n\n\n\n
The inspections were conducted during 2024\u20132025 among banking and investment services brokers selected on the basis of their individual risk profiles. They included both on-site and off-site inspections.<\/p>\n\n\n\n
The FSMA examined, among other areas:<\/p>\n\n\n\n
The FSMA observed improvements in the formalisation and quality of certain policies and procedures. However, it also identified shortcomings, primarily relating to business-wide risk assessments, customer identification, understanding the nature and purpose of business relationships, and the consistent implementation of AML\/CFT obligations.<\/p>\n\n\n\n
The FSMA expects the business-wide risk assessment to reflect the firm’s actual activities, taking into account factors such as customers, products, services, geographical risks and distribution channels.<\/p>\n\n\n\n
For intermediaries operating under multiple regulatory authorisations or registrations, the FSMA also emphasises that a separate business-wide risk assessment must be conducted for each activity subject to AML\/CFT legislation.<\/p>\n\n\n\n
The FSMA repeatedly identified shortcomings in the alignment between business-wide risk assessments, risk categories and individual customer risk assessments.<\/p>\n\n\n\n
These elements must be logically connected, and the due diligence measures applied must be proportionate to the identified risks. Any update to the business-wide risk assessment should also trigger a review of the methodology used for individual customer risk assessments.<\/p>\n\n\n\n
Procedures must clearly specify which persons must be identified, what information must be collected, when identity verification must take place and under which conditions verification may exceptionally be deferred.<\/p>\n\n\n\n
Intermediaries must also obtain sufficient information about the customer’s characteristics and the purpose and intended nature of the business relationship. The extent of these assessments must be proportionate to the customer’s individual risk profile.<\/p>\n\n\n\n
Enhanced due diligence measures must also be sufficiently detailed, particularly for politically exposed persons (PEPs) and other situations classified as high risk under the applicable legislation.<\/p>\n\n\n\n
The FSMA expects unusual transactions to be subject to specific analysis, additional information to be obtained where necessary, and the assessment to be documented in writing under the responsibility of the AMLCO.<\/p>\n\n\n\n
Compliance with financial sanctions was also covered by the inspections. The FSMA identified shortcomings relating to the definition of required measures and the existence or adequacy of monitoring and control systems.<\/p>\n\n\n\n
As a good practice, the FSMA recommends referring to the up-to-date financial sanctions lists available on the website of the Belgian Treasury.<\/p>\n\n\n\n
The FSMA draws a clear distinction between the adequacy of procedures and the effectiveness of their implementation.<\/p>\n\n\n\n
A procedure may be appropriate in substance but still give rise to compliance deficiencies if it is not consistently applied or if the measures taken are insufficiently documented.<\/p>\n\n\n\n
This applies, among other areas, to individual customer risk assessments, customer identification, updating customer information and compliance with financial embargoes.<\/p>\n\n\n\n
The FSMA therefore emphasises that a formally established AML\/CFT framework can only be effective if the prescribed measures are implemented in practice.<\/p>\n\n\n\n
The supervisory authority identified discrepancies between internal policy documents, risk assessments and information submitted through CABRIO, periodic AML\/CFT questionnaires or other regulatory information requests.<\/p>\n\n\n\n
The FSMA considers such consistency an essential component of an effective risk-based approach.<\/p>\n\n\n\n
Intermediaries are therefore advised to verify that their internal documentation, operational practices and regulatory submissions are aligned.<\/p>\n\n\n\n
Although the inspections were not conducted in the insurance sector, the report provides a useful reference for insurance intermediaries subject to AML\/CFT legislation.<\/p>\n\n\n\n
It clearly demonstrates that the FSMA does not merely assess whether formal procedures are in place, but also examines their adequacy, consistency and demonstrable implementation in practice.<\/p>\n\n\n\n
These findings can therefore serve as a basis for an internal review of the firm’s AML\/CFT framework.<\/p>\n\n\n\n
From 10 July 2027, Regulation (EU) 2024\/1624 on the prevention of the use of the financial system for money laundering or terrorist financing will become directly applicable.<\/p>\n\n\n\n
Becobra is actively preparing for the implications of this new regulatory framework for the insurance brokerage sector.<\/p>\n\n\n\n
Together with the other relevant industry associations, Becobra is working on revising the existing sector-wide agreement governing cooperation between insurers and insurance intermediaries in meeting AML\/CFT obligations.<\/p>\n\n\n\n
In parallel, each firm is responsible for reviewing its own bilateral arrangements with insurers, which exist alongside the sector-wide agreement, and adapting them where necessary to comply with the new regulatory framework.<\/p>\n\n\n\n
Becobra is also assessing which additional initiatives could help its members prepare for and implement the new European requirements.<\/p>\n\n\n\n
Do you have questions, comments or specific concerns regarding the application of AML\/CFT obligations? We encourage you to share them with us. The practical experience of our members provides valuable input for further industry discussions.<\/p>\n\n\n\n
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