Bulletin: BH2022003

Dear Agents:

Please ensure you collect sufficient information to i) establish the identity of the client/policyholder and to ii) assess and verify as to whether the client/policyholder is considered a low, medium, or high-risk, which may warrant further or enhanced due diligence review. If you deem the transaction risk to be medium or high, please speak to a Stewart underwriter immediately.

In compliance with Stewart Bulletin SLS00158 (concerning the USA Patriot Act and Executive Order No. 13224), a Specially Designated Nationals and Blocked Persons (“SDN List”) review must be performed on every transaction.  Stewart has created a searchable database that you can check against and document your results.

1. Go to Stewart’s Special Alerts Database: specialalerts.stewart.com
2. Select for “Database Search” (left of the page) to check results against each person’s name. 

Please verify that all parties to the closing (seller, buyer, borrower, individual, foreign lender, or other party receiving any significant funds from closing) do not appear on the SDN List and note in your records that the SDN List search is clear. If your search results in a match of name or other circumstances reasonably arouse your suspicion, immediately take the following actions:

1. Notify Stewart at STLBahamas@stewart.com of the flagged transaction.
2. Complete all applicable sections of Appendix F of the ICB’s Suspicious Transaction Report form (See: AML-CFT-PF-Guidelines-for-Insurance-Companies-Sept-2018-1.pdf (insurancecommissionbahamas.com)) 
3. You must also contact the U.S. Office of Foreign Assets Control at 1-800-540-6322 or 202-622-2490 for further instructions before either closing or refusing to close the transaction.

Do not simply refuse to close before calling both Stewart and OFAC. Never disclose to the parties to the transaction that you have a match with a name on the SDN List.

PDF Download: ICB Suspicious Transaction Report Form (Appendix F)