The Insurance and Social Security Supervisory Authority (ACAPS) and Bank Al-Maghrib (BAM), in their guide on the anti-money laundering regime and the financing of terrorism (LBC-FT), support the concept of “third party introduction”

The guide is a summary of the regulatory provisions relating to third party introduction as provided for by ACAPS and BAM in their respective regulatory frameworks. Thus, the implementation of due diligence obligations relating to the identification, verification of the identity of the client and, where appropriate, of the beneficial owner and the preservation of the related documents, is ensured by the submitting third party, in this case. the bank marketing insurance products, on behalf of the institution relying on the third party, namely the insurance undertaking. The bank remains responsible to the latter for these due diligence obligations. The third party initiator must be subject to legislation and regulations relating to the LBC/FT. However, third-party introduction must be separated from outsourcing, which consists in an insurance company using an external entity to carry out customer due diligence. The guide also mentions the responsibilities of the introducing third-party bank as well as that of the insurance undertaking.