Instruction No. 2010-I-04 of September 29, 2010, on information regarding anti-money laundering and terrorist financing prevention measures for insurance companies (repealed)

PRUDENTIAL CONTROL AUTHORITY Instruction No. 2010-I-04 regarding information on the anti-money laundering and terrorist financing prevention system concerning insurance companies

The Prudential Control Authority, Having regard to the Insurance Code, particularly Books III of the Legislative Part, the Regulatory Part and the Regulatory Part-Decrees; Having regard to the Monetary and Financial Code, particularly Chapters I and II of Title VI of Book V; Having regard to the opinion of the Anti-Money Laundering Consultative Committee dated September 22, 2010; Decides:

Article 1 The following are hereinafter referred to as "subject entities": insurance companies exercising direct insurance activity mentioned in Article L. 310-1 of the Insurance Code, which carry out insurance operations falling under branches 20 to 26 mentioned in Article R. 321-1 of the same Code.

Subject entities must submit the ANTI-MONEY LAUNDERING INSURANCE tables from Annex 1 to this instruction: – B1 – internal procedures; – B2 – identity of the person responsible for implementing the anti-money laundering and terrorist financing risk assessment and management system mentioned in Article R.561-38 I 1° of the Monetary and Financial Code, identity of Tracfin declarants and identity of Tracfin correspondents; – B3 – list of branches and subsidiaries established abroad; – B4 – comments.

An explanatory note on how to complete the ANTI-MONEY LAUNDERING B1 to B4 tables is provided in Annex 2.

Article 2 The information provided in the tables mentioned in Article 1 is finalized on October 31, 2010. The information filled in the ANTI-MONEY LAUNDERING B2 table is finalized on the date of sending to the General Secretariat of the Prudential Control Authority.

Instruction No. 2010-I-04 regarding information on the anti-money laundering and terrorist financing prevention system concerning insurance companies Prudential Control Authority 2

Article 3 The tables are prepared under the responsibility of the persons in charge of running the company mentioned in Article L. 321-10 of the Insurance Code.

They must be sent no later than December 17, 2010 to the General Secretariat of the Prudential Control Authority: – on paper, signed by at least one of the persons in charge of running the company mentioned in Article L. 321-10 of the Insurance Code; – and in electronic form (email).

Furthermore, in the event of the designation of one or more Tracfin declarants or correspondents during the year, the updated data regarding the identity of Tracfin declarants and correspondents included in table B2 mentioned in Article 1 must be sent to the General Secretariat of the Prudential Control Authority using the same transmission methods.

Article 4 Subject entities must keep the collected information and all documents used to prepare it available to the General Secretariat of the Prudential Control Authority for a period of five years from their date of transmission.

Paris, September 29, 2010 The President of the Prudential Control Authority, [Christian NOYER]

ANTI-MONEY LAUNDERING INSURANCE Tables.xls / 1 INSURANCE COMPANIES COMPANY REGISTRATION NUMBER SIREN ANTI-MONEY LAUNDERING TABLE B1 Unless otherwise indicated, the articles cited in the questionnaire refer to the Monetary and Financial Code (CMF). The questionnaire also refers to the Insurance Code (C.Ass) and the Tax Procedure Code (LPF).

ARTICLE ARTICLE 1 1.1 Has your company designated a person responsible for implementing the anti-money laundering and terrorist financing risk assessment and management system provided for in Article L.561-32? R. 561-38 I 1° 1.2 Is the person responsible for implementing this system a member of your management? R. 561-38 I 1° 1.3 Does the person responsible for implementing this system regularly report on their activities to the persons in charge of running the company mentioned in Article L. 321-10 of the C.Ass? 1.4 Are the names of TRACFIN declarants communicated without delay: R. 561-23 1.4.1 - to TRACFIN? 1.4.2 - to the General Secretariat of the ACP? 1.5 Are the names of TRACFIN correspondents communicated without delay: R. 561-24 1.5.1 - to TRACFIN? 1.5.2 - to the General Secretariat of the ACP? 1.6 Please fill in the ANTI-MONEY LAUNDERING B2 table with the identity of the person responsible for implementing the anti-money laundering and terrorist financing risk assessment and management system provided for in Article L.561-32, as well as the identity of the declarants and TRACFIN correspondents. 1.7 Do your procedures provide for notifying the General Secretariat of the ACP and TRACFIN without delay of any modification concerning the identity of the declarants and TRACFIN correspondents? R. 561-23 and R. 561-24 1.8 Does the identity of the declarants and TRACFIN correspondents appear in your company's internal written rules (for example, in the AML-CFT procedures)? 1.9 Are any modifications concerning the declarants or TRACFIN correspondents (designation of new declarants or correspondents, change of contact details, etc.) communicated without delay to your company's staff? 1.10 Does your company ensure that the declarants and TRACFIN correspondents communicate to each other the information brought to their attention by TRACFIN and keep themselves informed of requests emanating from them? R.561-27 1.11 Do your procedures provide that the declarants and TRACFIN correspondents keep the person responsible for implementing the anti-money laundering and terrorist financing risk assessment and management system informed of declarations transmitted to TRACFIN as well as requests and information brought to their attention by TRACFIN? Does your company's activity relate exclusively to operations covered by Article R. 561-16 of the CMF, pursuant to Article L. 561-9 II of the same Code? Enter your registration number and SIREN Question No. ACTIVITY ANTI-MONEY LAUNDERING AND TERRORIST FINANCING QUESTIONNAIRE (AML-CFT) GOVERNANCE, DECLARANTS AND TRACFIN CORRESPONDENTS ORGANIZATION RESPONSES RESPONSES Instruction No. 2010-I-04 regarding information on the anti-money laundering and terrorist financing prevention system concerning insurance companies Annex 1 Prudential Control Authority 3

ANTI-MONEY LAUNDERING INSURANCE Tables.xls / 2.1 Has your company developed a classification of anti-money laundering and terrorist financing risks? R. 561-38 I 2° 2.2 Does this risk classification take into account the following elements: R. 561-38 I 2° of the CMF and A. 310-8 I of the C.Ass 2.2.1 - the nature of the products or services offered? 2.2.2 - the characteristics of the counterparties? 2.2.3 - the specific conditions of the operations (for example, nature, complexity, location)? 2.2.4

• the marketing method or distribution channels used (outsourcing, remote relationship, insurance intermediary, etc)? 2.3 Do your procedures provide that the risk classification is updated regularly and following in particular any event significantly affecting activities, clientele, subsidiaries or establishments? A. 310-8 I of the C.Ass 2.4 Do your procedures take into account the risk classification to adapt, according to the degree of exposure and the nature of the risks incurred: R. 561-38 I 3° of the CMF and A. 310-8 VI of the C.Ass 2.4.1
• the identification of counterparties - as well as payers if they are different -, the beneficial owners if applicable, and beneficiaries? 2.4.2 - the knowledge of counterparties and the beneficial owners if applicable? 2.4.3 - the monitoring measures for operations? 2.5 Does the risk classification allow distinguishing: 2.5.1
• persons, products or operations that meet the conditions of Articles R. 561-15 and R. 561-16, within the meaning of Article L. 561-9 II? L. 561-9 II 2.5.2
• situations, other than those mentioned in Articles R. 561-15 and R. 561-16, for which you consider that the risk of anti-money laundering or terrorist financing is low within the meaning of Article L. 561-9 I? L. 561-9 I 2.5.3
• situations for which additional vigilance measures must be carried out within the meaning of Article L. 561-10? L. 561-10 2.5.4
• persons, products or operations other than those covered by Article L561-10, for which you consider that the risk of anti-money laundering or terrorist financing is high, within the meaning of Article L. 561-10-2 I? L. 561-10-2 I 3 3.1 Is there a written document adapted to your activity within your company, including when your company belongs to a group, describing the internal procedures related to AML-CFT? A. 310-8 II of the C.Ass 3.2 Do your AML-CFT procedures include: 3.2.1
• specific elements related to the implementation of the anti-terrorist financing system? 3.2.4 - a list of indicators of suspicious or risky operations? 3.3 Has Ordinance No. 2009-104 of January 30, 2009 and the implementing decrees and orders led to the updating of your AML-CFT procedures? 3.4 Are your AML-CFT procedures updated, particularly following organizational changes in your company, changes in your risk classification or regulatory changes? 3.5 Specify the date of the last update of the written document describing the AML-CFT procedures: 3.6 Have your AML-CFT procedures been disseminated to all your employees? 3.7 Do your AML-CFT procedures cover all activities of the company (operational entities, activities extending insurance activities, placement activities, contract management activities or essential services outsourced, etc)? 3.8 Do your AML-CFT procedures apply to your general insurance agents? RISK CLASSIFICATION PROCEDURES RELATING TO ANTI-MONEY LAUNDERING AND TERRORIST FINANCING (AML-CFT) RECRUITMENT, INFORMATION AND TRAINING Instruction No. 2010-I-04 regarding information on the anti-money laundering and terrorist financing prevention system concerning insurance companies Annex 1 Prudential Control Authority 4

ANTI-MONEY LAUNDERING INSURANCE Tables.xls / 3 4.5 Does all the concerned staff of your company benefit from regular training and information to update their AML-CFT knowledge? L. 561-33 4.6 Do your procedures provide that the delivery of AML-CFT training is subject to traceability of the funding? 4.7 Have the trainings been broken down into different versions according to the activities actually performed? 4.8 Specify the date of the last AML-CFT training delivered to staff: 4.9 Indicate the proportion of people trained on the new legislative context since the publication of Ordinance No. 2009-104 of January 30, 2009, compared to all staff, as of October 31, 2010: 5 5.1 Does your company carry out periodic reviews of the AML-CFT system? R.561-38 I 5° of the CMF and A.310-9 I of the C.Ass 5.2 Are the persons in charge of the periodic review hierarchically and functionally independent from the person responsible for implementing the anti-money laundering and terrorist financing risk assessment and management system provided for in Article L. 561-32? 5.3 Do your procedures provide that the results of the periodic reviews are the subject of a report communicated: A.310-9 I of the C.Ass 5.3.1 - to the persons in charge of running the company mentioned in Article L. 321-10 of the C.Ass? 5.3.2

• to the person responsible for implementing the anti-money laundering and terrorist financing risk assessment and management system provided for in Article L. 561-32? 5.3.3 - to the TRACFIN correspondents? 5.4 Indicate the date of the last periodic review that covered AML-CFT: 5.5 Does your company implement permanent monitoring of the AML-CFT system, in particular to take, if necessary, appropriate measures to correct observed anomalies? R. 561-38 I 5° of the CMF and A. 310-9 II of the C.Ass 5.6 Do your procedures provide that the record of the conclusions of the permanent monitoring and the anomalies observed is regularly sent: A. 310-9 II of the C.Ass 5.6.1
• to the person responsible for implementing the anti-money laundering and terrorist financing risk assessment and management system provided for in Article L.561-32? 5.6.2 - to the TRACFIN correspondents? 5.7 Does the 2010 internal control annual report include the following sections: R. 336-1 of the C.Ass and A. 310-9 III of the C.Ass 5.7.1 - a summary of your AML-CFT organization and procedures? 5.7.2 - a summary of the permanent monitoring work? 5.7.3 - the anomalies observed by the permanent monitoring? 5.7.4 - the corrective measures taken? 5.7.5 - the conclusions of the possible periodic review? 5.8 Do your procedures provide that you regularly monitor the compliance of the AML-CFT systems implemented by brokers and other insurance intermediaries with whom you have a business relationship? L. 561-7 of the CMF and R. 336-1 of the C.Ass 5.9 Do your procedures provide that you regularly monitor the compliance of the AML-CFT systems implemented by your general insurance agents? R. 336-1 of the C.Ass 5.10 Does the AML-CFT internal control system apply to all your essential outsourced services other than those related to marketing? R. 336-1 of the C.Ass 6 6.1 Do your procedures provide that the following are kept for at least 5 years from the cessation of the business relationship: L. 561-12 6.1.1
• documents relating to the verification of the identity of counterparties - as well as payers if they are different -? 6.1.2 - documents relating to the verification of the identity, if applicable, of the beneficial owners? R. 561-7 6.1.3 - documents relating to the verification of the identity of beneficiaries? 6.1.4
• suspicious declarations related to the business relationship and, if applicable, the attachments, as well as the TRACFIN acknowledgments of receipt of suspicious declarations made? ACP-TRACFIN guidelines 6.2 Do your procedures provide that documents relating to operations carried out are kept for a period of at least 5 years from the execution of said operations (premium, waiver, termination, surrender, advance, reduction, pledge, payment, etc)? L. 561-12 DOCUMENT RETENTION INTERNAL CONTROL Instruction No. 2010-I-04 regarding information on the anti-money laundering and terrorist financing prevention system concerning insurance companies Annex 1 Prudential Control Authority 5

ANTI-MONEY LAUNDERING INSURANCE Tables.xls / 4 6.3 Do your procedures provide that the information and evidence obtained during the enhanced examination of operations mentioned in Article L. 561-10-2 II are kept for at least 5 years from the execution of said operations? L. 561-12 and R. 561-22 6.4 Do your procedures provide that identification and vigilance documents relating to policyholders - as well as payers if they are different -, if applicable to beneficial owners, and to beneficiaries of anonymous capitalization bonds are kept for at least 6 years from the date of repayment? L. 102 B of the LPF 6.5 Are the documents related to AML-CFT kept in such a way that they are immediately accessible to satisfy the exercise of the right of communication by TRACFIN and by the ACP? 7 7.1 Is your company part of a group as defined in Article L.511-20 III of the CMF and Article L.334-2 of the C.Ass? 7.2 In the event that your company belongs to a group: 7.2.1 - is the TRACFIN declarant of your company designated at the group level? R. 561-28 7.2.2 - is the TRACFIN correspondent of your company designated at the group level? R. 561-28 7.3 Do your procedures provide that the entities composing your group exchange the following information necessary for the organization of vigilance within the group: R. 561-29 7.3.1

• information relating to the identity of counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries? 7.3.2
• information relating to the knowledge of counterparties, and if applicable beneficial owners? 7.5 If your insurance company is a French subsidiary or branch whose headquarters is located abroad, does it possess all the elements relating to the identity of counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries, including those in relation with other companies of the group? R. 561-29 7.6 Does your company's internal rules contain the procedure to be followed to ensure information exchanges concerning the existence and content of suspicious declarations within your group under the conditions provided for in Article L.561-20? L. 561-20 7.7 Do your company's internal rules apply to the entities of your group that are subject to the same obligations: 7.7.1
• in France, in the European Union and in the European Economic Area, or in a third country equivalent listed in point 2° of II of L.561-9 under the conditions provided for in Article L. 561-20? L. 561-20 7.7.2 - in other countries than those mentioned in the previous question? 7.8 Is the internal control of the AML-CFT system applicable to all your subsidiaries and/or branches and/or affiliated companies? R. 336-1 of the C.Ass 7.9 Does your company apply in its foreign branches measures at least equivalent to those in force in France regarding vigilance towards counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries, and regarding the retention of information? L. 561-34 7.10 Does your company ensure the application in its foreign subsidiaries of measures equivalent to those in force in France regarding vigilance towards counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries, and the retention of information? L. 561-34 7.11 Does your company have subsidiaries and/or branches in countries where the locally applicable law does not allow them to implement measures equivalent to those in force in France regarding vigilance towards counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries, and regarding the retention of information? 7.12 Does your company inform TRACFIN when the locally applicable law does not allow it to implement equivalent measures regarding vigilance towards counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries, and regarding the retention of information in its subsidiaries and/or branches located abroad? L. 561-34 7.13 Does your company communicate the minimum appropriate measures regarding AML-CFT to its subsidiaries (held or controlled by more than 50%) and/or its branches located abroad? L. 561-34 Please specify in the ANTI-MONEY LAUNDERING B3 table the list of your subsidiaries and/or branches located in countries where local provisions oppose provisions related to AML-CFT. ARTICLE 8 Question No. CLIENT RELATIONSHIP PROCEDURES INTRA-GROUP RELATIONSHIPS CLIENT RELATIONSHIP - VIGILANCE SYSTEM RESPONSES Instruction No. 2010-I-04 regarding information on the anti-money laundering and terrorist financing prevention system concerning insurance companies Annex 1 Prudential Control Authority 6

Tableaux BLANCHIMENT ASSUR.xls / 5 8.1 Do your procedures provide for identifying and verifying the identity of all new counterparties before entering into a business relationship? L.561-5 8.2 If applicable, do your procedures provide for identifying and verifying the identity of beneficial owners before entering into a business relationship? L.561-5 8.3 If applicable, do your procedures provide for verifying the identity of payers if they are different from the counterparties? L.561-5 8.4 Is Article A. 310-5 of the Insurance Code applied? 8.5 Do your procedures provide for verifying the identity and authority of persons acting on behalf of counterparties? R. 561-5 8.6 In the event of the subscription of an insurance contract, do your procedures provide for verifying the identity of the beneficiary of the contract at the latest at the time of payment of the benefit to the beneficiary? R. 561-6 8.7 Do your procedures provide for gathering knowledge elements regarding counterparties and, if applicable, beneficial owners, before entering into a business relationship? L. 561-6 8.8 Do your procedures provide for not pursuing a business relationship in the absence of: L. 561-8 8.8.1 - identification of one of the counterparties - as well as payers if they are different - ? 8.8.2 - identification of one of the beneficial owners? 8.8.3 - information regarding the nature and object of the business relationship? 8.9 Have you organized the updating of active business relationship files, in order to satisfy the new obligations regarding the knowledge of persons introduced in 2009? Article 19 of Ordinance n°2009-104 of January 30, 2009 8.10 Please specify in the "tableau blanchiment B4" (comments table) the progress regarding the updating of active business relationship files in order to satisfy these new obligations. 8.11 Do your procedures provide for updating the identification and knowledge elements of the business relationship? R. 561-11 9 9.1 Outside the hypotheses of application of Article A.310-5 of the Insurance Code, do your procedures provide for verifying, before entering into a business relationship, the identity of counterparties - as well as payers if they are different - natural persons upon presentation of: R. 561-5 9.1.1 - a valid official identity document (identity card, passport, etc.)? 9.1.2 - another document? 9.2 Do your procedures provide, for a natural person, to record and retain the following mandatory mentions: R. 561-5 9.2.1 - information relating to the person (names, first names, date and place of birth)? 9.2.2

• information relating to the proof of identity (nature, date and place of issue, name and title of the authority having issued the document and, if applicable, having authenticated it)? 9.3 Outside the hypotheses of application of Article A.310-5 of the Insurance Code, do your procedures provide for systematically verifying before entering into a business relationship, the identity of counterparties - as well as payers if they are different - legal persons upon communication of the original or a copy of any act or extract from an official registry dated less than three months confirming the name, legal form and registered office address, the identity of partners and corporate officers? R. 561-5 9.4 Do your procedures provide for retaining the elements attesting that the payment of the first premium was made by debit from an account opened in the name of the counterparty with a credit institution subject to the provisions of Article A.310-5 of the Insurance Code? L. 561-12 10 10.1 When one of the counterparties - as well as the payer if different - is a legal person, do your procedures provide for verifying, using probative documents, the identity: L.561-5 10.1.1
• of natural persons who directly or indirectly hold more than 25% of the capital or voting rights of the counterparty - as well as the payer if different - ? R. 561-1, R. 561-2 and R. 561-3 10.1.2
• of any other natural person who exercises control power over the management, administration, or direction bodies of the company or over the general meeting of its partners? R. 561-1 11 11.1 Does your company use regulated intermediaries to distribute its products (third-party introducers within the meaning of Article L561-7)? L. 561-7 I 11.2 Has your company put in place procedures to ensure that the third parties to which it calls upon meet the conditions set forth in Article L. 561-7 I? 11.3 When your clients are introduced by third parties, are these latter responsible for collecting and verifying on your behalf the information relating to: 11.3.1 - the identity of counterparties - as well as payers if they are different -? L. 561-7 I 11.3.2 - the identity, if applicable, of beneficial owners? L. 561-7 I 11.3.3 - the knowledge of counterparties, and if applicable, beneficial owners? L. 561-7 I THIRD-PARTY INTRODUCTION IDENTIFICATION BENEFICIAL OWNER Instruction n° 2010-I-04 relating to information on the device for preventing money laundering and the financing of terrorist activities concerning insurance companies Annex 1 Prudential Control Authority 7

Tableaux BLANCHIMENT ASSUR.xls / 6 11.3.4 - the object and nature of the business relationship? L.561-7 11.4 Are these information elements made available to your company without delay by the third parties? R. 561-13 11.5 Are the copies of identification documents of counterparties - as well as payers if they are different -, if applicable, beneficial owners, as well as any relevant document concerning the information elements transmitted at the first request of your company by the third parties? R. 561-13 11.6 Has your company signed an agreement defining the terms of transmission of the collected elements and control of the diligence implemented with the third parties to which your company calls upon? R. 561-13 11.7 Do you present to other regulated persons persons on whom you have already carried out diligence (identification, object and nature of the business relationship, knowledge)? L. 561-7 I 11.8 Do your procedures provide for the conditions under which your company is authorized to communicate to regulated third parties information relating to the identification and knowledge of your counterparties - as well as payers if they are different -, if applicable beneficial owners? L. 561-7 I 12 12.1 Before entering into a business relationship, do your procedures provide for gathering information relating to the object and nature of the relationship? R. 561-12 12.2 Do the information to be collected regarding the object and nature of the business relationship concern: R. 561-12 12.2.1 - the amount and nature of the envisaged operations? 12.2.2 - the source of funds? 12.2.3 - other elements? 12.3 Before entering into a business relationship, do your procedures provide for gathering information on the professional, economic and financial situation of counterparties and if applicable, beneficial owners? R. 561-12 Do these information concern: Arrêté du 2 September 2009 12.3.1 - professional activities currently or previously exercised? 12.3.2 - revenues or any element allowing to estimate other resources? 12.3.3 - the patrimonial or financial situation? 12.3.4 - other elements? 12.4 Please specify in the BLANCHIMENT B4 table the other information elements that your AML-CFT procedures provide for collecting on counterparties and, if applicable, on beneficial owners. 12.5 Is the information collection process formalized by the use of a standard knowledge form for counterparties and, if applicable, beneficial owners? ARTICLE 13 13.1 Do your procedures provide for benefiting from the regime provided for in Articles R. 561-15 and R. 561-16, in matters: L. 561-9 II 13.1.1

• identification of counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries? 13.1.2 - knowledge of counterparties, and if applicable, beneficial owners? 13.2 Do your procedures provide for collecting sufficient information to establish if the counterparties or the product meet the conditions required to benefit from the regime provided for in Articles R. 561-15 and R. 561-16? R. 561-17 13.3 Even if the activity of your company concerns exclusively operations referred to in Article R. 561-16, do your procedures nevertheless provide for measures: 13.3.1
• identification of counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries? 13.3.2 - knowledge of counterparties, and if applicable, beneficial owners? 14 14.1 In the event of low money laundering risk identified by your risk classification, other than those provided for in II of L. 561-9, do your procedures provide for: L. 561-9 I 14.1.1 - identifying counterparties - as well as payers if they are different - and beneficiaries? 14.1.2 - identifying, if applicable, beneficial owners? 14.1.3
• applying a reduced level of knowledge of counterparties, if applicable beneficial owners? CLIENT RELATIONSHIP - VIGILANCE DEVICES IN LOW RISK SITUATION IDENTIFICATION OF THE OBJECT AND NATURE OF THE BUSINESS RELATIONSHIP AND CLIENT KNOWLEDGE Question N° VIGILANCE DEVICE IN LOW RISK SITUATION WITHIN THE MEANING OF ARTICLE L.561-9 II VIGILANCE DEVICE IN LOW RISK SITUATION WITHIN THE MEANING OF ARTICLE L561-9 I ANSWERS Instruction n° 2010-I-04 relating to information on the device for preventing money laundering and the financing of terrorist activities concerning insurance companies Annex 1 Prudential Control Authority 8

Tableaux BLANCHIMENT ASSUR.xls / 7 14.1.4 - identifying the object and nature of the business relationship? ARTICLE 15 15.1 Do your procedures provide for applying complementary identification measures in the presence of: L. 561-10 15.1.1

• a counterparty or legal representative who is not physically present for the purpose of identification, notably in the case of distance selling? 15.1.2 - a politically exposed person as defined by Article R.561-18? 15.1.3 - an anonymous capital bond? 15.1.4
• an operation for own account or for account of third parties carried out with natural or legal persons, including their subsidiaries or establishments, domiciled, registered or established in a State or territory mentioned in VI of Article L561-15? 15.2 Do your procedures provide for implementing at least one of the following measures, to ensure the identity of counterparties: R. 561-20 I 15.2.1
• obtaining additional supporting documents allowing to confirm the identity of the person with whom your company is in a business relationship? 15.2.2
• implementing verification and certification measures of the copy of the official document by a third party independent of the person to be verified? 15.2.3
• requiring that the first payment of operations be made from or to an account opened in the name of the payer with a person mentioned in 1° to 6° of Article L.561-2 established in a Member State of the European Union or in a State party to the agreement on the European Economic Area? 15.2.4
• obtaining confirmation of the identity from a person mentioned in 1° to 6° of Article L.561-2 established in a Member State of the European Union or in a State party to the agreement on the European Economic Area? 16 16.1 Do your procedures provide for determining if counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries residing abroad, or direct members of their family or persons closely associated with them, occupy or have occupied political functions within the meaning of Article R.561-18: L.561-10, R. 561-18 and R.561-20 III 16.1.1 - upon entering into a business relationship? 16.1.2 - upon updating client files? 16.1.3
• at the time of payment of the benefit to the beneficiary other than the policyholder, or at the moment when he intends to exercise the rights conferred by the contract? 16.2 In the presence of a PEP, do your procedures provide for: 16.2.1
• searching for the origin of the patrimony and the origin of funds involved in the business relationship or transaction? R. 561-20 III 16.2.2
• gathering information regarding its environment, its functions or any element allowing to appreciate the nature of its links? R. 561-12 and arrêté du 2 September 2009 16.3 Do your procedures provide that entering into a business relationship with a PEP within the meaning of Article R.561-18 is authorized by a member of your executive body or by a person duly authorized to this effect by your executive body? R. 561-20 III 17 17.1 Does your company offer the possibility to subscribe to capital bonds? 17.2 Does your company offer the possibility to subscribe to anonymous capital bonds? 17.3 Does your company have a portfolio of anonymous capital bonds? 17.4 Indicate the turnover represented by the marketing of anonymous capital bonds in 2009: 17.5 Is there a separate register of anonymous capital bonds? L. 561-14-2 17.6 Is the identity of subscribers systematically recorded in this register? L. 561-14-2 17.7 Is the identity of beneficiaries of reimbursements systematically recorded in this register? L. 561-14-2 18 18.1 In the event of high money laundering or terrorist financing risk identified by your risk classification, do your procedures provide for: L.561-10-2 I 18.1.1
• intensifying identification measures of counterparties - as well as payers if they are different -, if applicable, beneficial owners, and beneficiaries? 18.1.2
• intensifying knowledge measures of counterparties, and if applicable, beneficial owners? 18.1.3
• increasing the frequency of updating and according to a defined periodicity of knowledge elements of counterparties, and if applicable, beneficial owners? 18.1.4 - intensifying identification measures of the object and nature of the business relationship? ARTICLE COMPLEMENTARY VIGILANCE DEVICE (L561-10) POLITICALLY EXPOSED PERSONS (PEP) OPERATIONS SURVEILLANCE Question N° CLIENT RELATIONSHIP - VIGILANCE DEVICES IN HIGH RISK SITUATION ANONYMOUS CAPITAL BONDS HIGH RISK DEVICE (L561-10-2 I) Question N° ANSWERS ANSWERS Instruction n° 2010-I-04 relating to information on the device for preventing money laundering and the financing of terrorist activities concerning insurance companies Annex 1 Prudential Control Authority 9

Tableaux BLANCHIMENT ASSUR.xls / 8 19 19.1 Has your company equipped itself with a monitoring and analysis device adapted to its activities, its clientele, its locations and the risks identified by the money laundering and terrorist financing risk classification? A. 310-8 VI of the Insurance Code 19.2 Does the monitoring device allow to follow and identify operations or business relationships inconsistent with the knowledge of counterparties, and if applicable, beneficial owners? L. 561-6 of the Financial and Monetary Code and A. 310-8 VI of the Insurance Code 19.3 Do your procedures provide for an examination of identified operations that would be inconsistent with the knowledge of counterparties, if applicable beneficial owners, and the object and nature of the contract? L. 561-6 19.4 Do your procedures provide for regular monitoring of business relationships classified under enhanced vigilance? L. 561-10-2 19.5 In the event of renunciation, do your procedures provide that funds are systematically returned to the account used to pay the premium amount? 19.6 Are cash payments accepted by your company? 19.7 Indicate the maximum possible annual threshold for cash payments: L.112-6 20 20.1 Do your procedures provide that a reinforced examination of any operation is carried out: L. 561-10-2 II 20.1.1 - particularly complex? 20.1.2 - of an unusually high amount? 20.1.3 - not appearing to have an economic justification? 20.1.4 - not appearing to have a lawful object? 20.2 Do the criteria for identifying operations requiring a reinforced examination cover notably: 20.2.1 - cash payments unitary or cumulative beyond a certain amount? 20.2.2 - operations beyond a certain amount carried out with non-residents? 20.2.3

• operations beyond a certain amount with countries or geographical areas that you consider risky or which are designated non-compliant by the FATF or by national authorities? 20.2.4
• contracts in the absence of an apparent relationship between counterparties - as well as payers if they are different -, if applicable beneficial owners, and beneficiaries? 20.2.5 - bank checks, notary checks or lawyer checks? 20.2.6
• checks of a significant amount relative to the business relationship, drawn by a third party non-counterparty? 20.2.7 - substitution of a third party to the contract for the regular payer? 20.3 Are other operational surveillance criteria defined in your procedures based on the risk classification? 20.4 Has compliance control integrated into its procedures for systematic prior approval of new products an appreciation of potential risks in terms of AML-CFT? 21 21.1 Do you possess computer tools that allow you to produce a statement of operations processed on behalf of a business relationship? L. 561-32 21.2 Do you possess computer tools that allow you to produce a statement of operations: L. 561-32 21.2.1
• carried out with countries or geographical areas that you consider risky or which are designated non-compliant by the FATF or by national authorities? 21.2.2 - carried out with non-residents? 21.2.3 - concerning cash exceeding a certain amount? 21.3 Do your surveillance tools allow to apprehend operations carried out for the same business relationship across multiple contracts? L. 561-32 21.4 Do you possess computer tools that allow you to detect operations: 21.4.1
• unusual with regard to the knowledge of counterparties, and if applicable, beneficial owners? 21.4.2 - of an unusually high amount? 22 22.1 During the reinforced examination of an operation, do your procedures provide that your company systematically inquires about: L. 561-10-2 II 22.1.1 - the origin of funds? 22.1.2 - the destination of these sums? 22.1.3 - the object of the operation? 22.1.4 - the identity of beneficiaries? 22.2 During the reinforced examination of an operation, do your procedures provide that your company verifies if the information obtained is consistent with the information it has regarding counterparties, if applicable beneficial owners, and beneficiaries? OPERATIONS SURVEILLANCE DEVICE OPERATIONS SURVEILLANCE CRITERIA OPERATIONS SURVEILLANCE TOOLS REINFORCED EXAMINATION OF OPERATIONS Instruction n° 2010-I-04 relating to information on the device for preventing money laundering and the financing of terrorist activities concerning insurance companies Annex 1 Prudential Control Authority 10

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22.3 Do your procedures provide for obtaining corroborating evidence in case of doubt as to the veracity of the information obtained or in case of inconsistency with the information you have regarding the counterparties, where applicable the beneficial owners, and the beneficiaries?

22.4 Indicate the number of files that have been subject to enhanced examination of transactions, with or without leading to the filing of a suspicious transaction report: 22.4.1 - in 2009 22.4.2 - during the first half of 2010

ARTICLE 23

23.1 Do your procedures provide for a suspicious transaction report to be filed with TRACFIN in the presence of sums or transactions that you know, suspect, or have good reasons to suspect: L. 561-15 I 23.1.1 - originate from an offense punishable by a prison sentence of more than one year? 23.1.2 - participate in the financing of terrorism?

23.2 Following the enhanced examination of certain transactions and the obtaining of supporting documents or additional information (L.561-10-2 II), do your procedures provide for filing a suspicious transaction report with TRACFIN in case of doubt regarding the information obtained? L. 561-15 III

23.3 Do your procedures provide that any transaction for which the identity of the order giver, the beneficial owner, or the settlor of a trust fund or any other asset management instrument remains doubtful despite the due diligence performed is systematically declared to TRACFIN? L.561-15 IV

23.4 Do your procedures provide that the person responsible for filing suspicious transaction reports with TRACFIN is informed when a business relationship is not pursued due to the impossibility of identifying or obtaining knowledge elements regarding the counterparties and, where applicable, the beneficial owners? L. 561-8 and R. 561-14

23.5 Do you systematically use the standard TRACFIN form to file a suspicious transaction report? The standard TRACFIN form can be downloaded from the following website: http://www.tracfin.minefi.gouv.fr/form_declar.htm

23.6 Do your procedures provide that the following mandatory information elements are filled in your suspicious transaction reports: R. 561-31 23.6.1 - the identity and contact details of the TRACFIN declarant? 23.6.2 - the identification and knowledge elements of the counterparties - as well as payers if they are different -, where applicable the beneficial owners, and the beneficiaries? 23.6.3 - the object and nature of the business relationship? 23.6.4 - the description of the transactions concerned? 23.6.5 - the analysis elements that led to establishing the business relationship? 23.6.6 - if the transaction has not yet been executed, its execution deadline? 23.6.7 - the analysis elements that led to declaring the transaction?

23.7 Does your company use tele-declaration to transmit its suspicious transaction reports to TRACFIN?

23.8 In the event of a suspicious transaction report, do your procedures provide for always sending to TRACFIN: R. 561-31 23.8.1 - information relating to the identification of the counterparties - as well as payers if they are different -, where applicable the beneficial owners, and the beneficiaries? 23.8.2 - information relating to the knowledge of the counterparties, and where applicable the beneficial owners? 23.8.3 - information justifying the suspicion?

23.9 Do your procedures provide that employees and executives, other than the declarants and TRACFIN correspondents, can take the initiative to file a suspicious transaction report in exceptional cases and due to urgency, in particular? R. 561-23

23.10 Do your procedures contain provisions regarding the confidentiality of the existence, content, and follow-up reserved for a suspicious transaction report: L. 561-19 and L. 561-26 23.10.1 - vis-à-vis the owner of the sums or the author of the transaction? 23.10.2 - vis-à-vis any other third party outside of the ACP?

23.11 Is any new information capable of invalidating, confirming, or modifying the elements contained in a suspicious transaction report brought to the knowledge of TRACFIN without delay? L. 561-15 V

23.12 Do your procedures provide for suspending the execution of a transaction for 24 hours following a suspicious transaction report, when that report is filed prior to the transaction? L. 561-16 and L. 561-25

23.13 Do your procedures provide that the suspension of the transaction is extended by 48 hours in case of opposition to the execution of the transaction by TRACFIN? L. 561-25

23.14 Do your procedures provide for the possibility of communicating the existence and content of a suspicious transaction report to another financial institution under the conditions provided for in L. 561-21, when you intervene for the same client and in the same transaction? L. 561-21

23.15 Indicate the number of suspicious transaction reports filed in: 23.15.1 - 2009 23.15.2 - 2008

Question No. SUSPICIOUS TRANSACTION REPORTS SUSPICIOUS TRANSACTION REPORTING MECHANISM RESPONSES

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23.15.3 - 2007

23.16 Specify the number of suspicious transaction reports related to the financing of terrorism filed: 23.16.1 - during the last five years 23.16.2 - in 2009

24

24.1 Do your procedures provide for filing a suspicious transaction report with TRACFIN in the presence of sums or transactions that you know, suspect, or have good reasons to suspect originate from tax fraud when there is the presence of at least one of the 16 criteria specified by the decree of July 16, 2009 (D.561-32-1 of the CMF)? L.561-15 II

24.2 Is the list of non-cooperative states and territories fixed by the order of the ministers in charge of the economy and budget: D.561-32-1 du CMF, Arrêté du 12/02/10 en application du 238-0 A du CGI et Instruction du 26/07/10 publiée au BO des impôts du 05/08/10 24.2.1 - taken into account to determine the level of risk or vigilance to be applied during the establishment of a business relationship (risk classification)? 24.2.2 - included in your control tools to detect tax fraud operations, and the transfer of profits to destinations with privileged taxation likely to fall within the scope of a suspicious transaction report to TRACFIN?

24.3 Are criteria relating to tax fraud, within the meaning of the decree of July 16, 2009, taken into account in your transaction monitoring procedures? D. 561-32-1

ARTICLE 25

25.1 Has your company put in place an adapted mechanism for its activities to verify that the counterparties - as well as payers if they are different -, where applicable the beneficial owners, and the beneficiaries are not subject to asset freezing measures under European or national regulations? L. 562-3

25.2 Does your monitoring mechanism allow for the identification of sums or transactions carried out by or on behalf of or for the benefit of persons subject to restrictive asset freezing measures: 25.2.1 - immediately? L. 562-3 25.2.2 - periodically? L. 562-3

25.3 Are you in possession of updated lists of persons subject to restrictive asset freezing measures? L .562-3 du CMF et A. 310-8 du C.Ass

ARTICLE 26

26.1 Does your company have a wealth management service? 26.2 Has your company and/or one of its subsidiaries and/or branches been sanctioned by a supervisory or regulatory authority abroad for failure to comply with obligations related to AML/CFT? 26.3 Does your company have subsidiaries and/or branches in a state or territory that is non-cooperative in tax matters? D.561-32-1 du CMF, Arrêté du 12/02/10 en application du 238-0 A du CGI et Instruction du 26/07/10 publiée au BO des impôts du 05/08/10 26.4 Does your company have subsidiaries and/or branches in a country that, in the sense of the FATF, presents strategic deficiencies in AML/CFT matters? 26.5 Does your company have subsidiaries and/or branches in a country that is subject to international financial sanctions? 26.6 What is the life insurance turnover generated by your subsidiaries (held at 50% or more) abroad? 26.7 What is the life insurance turnover generated by your subsidiaries and branches located in the DOM-ROM and COM (French Overseas Territories)? 26.8 What percentage of turnover represents the online sale of your life insurance products?

TAX FRAUD VARIOUS INFORMATION

Question No. ASSET FREEZING MECHANISM AND TOOLS Question No. RESPONSES RESPONSES

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SIGNATORY FUNCTION DATE SIGNATURE OF THE PERSON RESPONSIBLE FOR MANAGING THE COMPANY UNDER ARTICLE L.321-10 OF THE INSURANCE CODE

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Subject-liable entities are required to communicate to TRACFIN and to the ACP the identity of their executives or agents authorized who:

• file suspicious transaction reports (declarants within the meaning of Article R.561-24 of the Monetary and Financial Code).
• are responsible for responding to requests from TRACFIN or the ACP (correspondents within the meaning of Article R.561-23 of the Monetary and Financial Code). Any change concerning authorized persons must be brought to the knowledge of TRACFIN and the ACP without delay (R.561-23 and R.561-24).

DATE DESIGNATION TITLE FIRST NAME LAST NAME AUTHORIZATION ADDRESS POSTAL CODE CITY TELEPHONE EMAIL

DATE DESIGNATION TITLE FIRST NAME ADDRESS POSTAL CODE CITY TELEPHONE EMAIL

Other / Remarks The information brought to our knowledge through this form will replace and cancel those previously communicated. We therefore thank you to fill out and pay particular attention to all sections of this form.

SIGNATORY FUNCTION DATE SIGNATURE OF THE PERSON RESPONSIBLE FOR MANAGING THE COMPANY UNDER ARTICLE L.321-10 OF THE INSURANCE CODE

SIREN: COMMUNICATION OF THE IDENTITY OF THE PERSON RESPONSIBLE FOR IMPLEMENTING THE ASSESSMENT AND MANAGEMENT MECHANISM FOR MONEY LAUNDERING AND TERRORISM FINANCING RISKS, MENTIONED IN ARTICLE R.561-38 I 1° OF THE MONETARY AND FINANCIAL CODE OTHER FUNCTION EXERCISED COMMUNICATION OF THE IDENTITY OF DECLARANTS AND TRACFIN CORRESPONDENTS

Company Name: Date: Registration Number: Company Category Tableau BLANCHIMENT B2 NAME OTHER FUNCTION EXERCISED

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Tableau BLANCHIMENT B3

COMPANY REGISTRATION NUMBER SIREN NAME TYPE COUNTRY Local provisions oppose AML/CFT obligations DATE OF EVENTUAL SANCTION OBJECT / NATURE OF SANCTION REMARKS

LIST OF FOREIGN SUBSIDIARIES AND BRANCHES

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Instruction n° 2010-I-04 relative aux informations sur le dispositif de prévention du blanchiment de capitaux et du financement des activités terroristes concernant les entreprises d’assurance Annexe 1 Autorité de contrôle prudentiel 16

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Tableau BLANCHIMENT B4

COMPANY REGISTRATION NUMBER SIREN Reference of the BLANCHIMENT table and question Company Comments COMMENTS

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Instruction n° 2010-I-04 relative aux informations sur le dispositif de prévention du blanchiment de capitaux et du financement des activités terroristes concernant les entreprises d’assurance Autorité de contrôle prudentiel 21 Annexe 2 EXPLANATORY NOTICE Questionnaire for insurance companies

1. Generalities 1.1. Presentation of the BLANCHIMENT ASSUR tables The questionnaire regarding the anti-money laundering and terrorist financing prevention mechanism for insurance companies comprises four BLANCHIMENT tables: – B1 – a table regarding internal procedures and other data to be filled in (dates, figures, etc.) ; – B2 – a table regarding the identity of the person responsible for implementing the assessment and management mechanism for money laundering and terrorism financing risks mentioned in Article R.561-38 I 1° of the Monetary and Financial Code, the identity of Tracfin declarants, and the identity of Tracfin correspondents ; – B3 – a table regarding the list of branches and subsidiaries established abroad ; – B4 – a comments table to accompany the responses given in the other tables, if necessary. The questionnaire is presented as a single file in electronic EXCEL format, Office 2003 version. These comments must specify the reference of the table and the question to which they relate.

1.2. Scope of the survey Insurance companies exercising direct insurance activity mentioned in Article L.310-1 of the Insurance Code, which carry out insurance operations falling under branches 20 to 26 mentioned in Article R.321-1 of the same Code, must respond to this questionnaire. These companies are hereinafter referred to as "entities".

1.3. Adaptation of the questionnaire to the activities of the entities When an entity carries out an activity exclusively concerning operations referred to in Article R.561-16 of the CMF, it is exempt from answering the grayed-out questions. Furthermore, when it answers NO or N/A to a question highlighted in yellow, the detailed questions related to it are automatically grayed out and do not need to be filled in.

1.4. Information collected The information filled in in the BLANCHIMENT B1 table as well as in the BLANCHIMENT B3 table is as of October 31, 2010. The information filled in in the BLANCHIMENT B2 table is as of the date of sending to the General Secretariat of the Prudential Control Authority. All questions, unless they have been grayed out, must receive an answer. The entity can answer by: – YES or NO (option indicated by the letter "A" in the answer box) ; – YES or NO or N/A (option indicated by the letter "B" in the answer box). The entire set of answers can be accompanied by comments, which must be drafted in the BLANCHIMENT B4 table. These comments must specify the reference of the table and the question to which they relate.

2. Clarifications regarding the content of the BLANCHIMENT tables 2.1. BLANCHIMENT B1 Table Question 2.2.2: The term counterparty refers to all interested parties to the contract, namely: the policyholders, the insured, the principals, and the accepting beneficiaries. Question 5.8: The entity must indicate if its procedures provide, according to frequency rules adapted to its activity and when circumstances justify it, the verification of the AML/CFT mechanism of brokers and other insurance intermediaries with which it works. Question 8.9: The entity must indicate if an action plan has been adopted to update customer knowledge elements within a reasonable timeframe, in accordance with Article 19 of Ordinance n°2009-104 of January 30, 2009. According to the Sectoral Application Principles adopted by the ACP 1 (sheet 3, section 2), business relationships are considered active as soon as an operation is carried out on the insurance contract (payment, surrender, advance request, advance repayment, pledge, etc.). Contracts subject to scheduled payments or surrenders are considered an active business relationship. Question 18.1.3: The entity must indicate if its procedures provide for an update of customer knowledge elements according to an adapted periodicity in the case of relationships presenting a high risk in accordance with the risk classification. This update can be carried out by direct inquiry of the client or by any other means such as verification of public data when relevant. Question 19.4: The entity must indicate if its procedures provide, in whatever form and according to an adapted periodicity, an enhancement of the monitoring of business relationships presenting a high risk. This point has been developed in the Sectoral Application Principles (sheet 3, section 1.4.2.2).

Question 20.2.4: The entity must indicate if it inquires about relationships that might exist between the different stakeholders in the insurance contract, in the case of complex operations without economic justification. The term beneficiary is to be understood in a broad sense. It also covers persons exercising a pledge, beneficiaries of a benefit, or a person requesting the refund of an anonymous capitalization bond.

1 The Sectoral Application Principles of the Prudential Control Authority regarding the fight against money laundering and terrorism financing for the insurance sector are available online on the Authority's official register, at the following address: http://www.banque-france.fr/acp/publications/documents/201007-principes-sectoriels-acp-blanchiment-assurances.pdf.

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Question 22.1: The destination of the sums in the context of enhanced examination concerns the economic use made of the funds. Question 22.1.4: The beneficiary referred to is the recipient of the sums involved in the transaction.

2.2. BLANCHIMENT B2 Table The information filled in in this table will update all the information previously transmitted by the entities to the Prudential Control Authority. The first box concerns the identity of the declarants and TRACFIN correspondents. The second box concerns the identity of the person responsible for implementing the assessment and management mechanism for money laundering and terrorism financing risks mentioned in Article R.561-38 I 1° of the Monetary and Financial Code.

2.3. BLANCHIMENT B3 Table The information on eventual sanctions concerns the field of money laundering and terrorism financing risk control. These can therefore also concern the general internal control mechanism.

3. Modalities for transmitting the questionnaire Entities are invited to download online on the official register of the Prudential Control Authority the questionnaire, at the following address: http://www.banque-france.fr/acp/publications/registre-officiel.htm. A printed and signed copy by at least one of the persons responsible for managing the company mentioned in Article L. 321-10 of the Insurance Code must be sent to the General Secretariat of the Prudential Control Authority, at the following address: Autorité de contrôle prudentiel - Mission de Lutte contre le blanchiment, 61 rue Taitbout, 75436 Paris Cedex 09. Entities must also submit the questionnaire in electronic format to the General Secretariat of the Prudential Control Authority, at the following address: cellule-lab@acp.banque-france.fr.