AML/CFT obligations for insurance companies and brokers in Algeria (2026)

A savings policy surrendered a few months after it was taken out, a beneficiary changed on the eve of a claim: the insurance sector offers launderers discreet tools to move funds and make them look legitimate. The AML/CFT obligations for insurance companies and brokers are designed precisely to close these doors, by requiring every player to know its clients, understand where the money comes from and report anything that cannot be explained.

The context makes this a priority. Algeria left the FATF grey list on 19 June 2026, but the next mutual evaluation, expected around 2029, will assess how effective frameworks really are, including outside the banking sector. With Regulation No. 01 of 6 November 2024 issued by the Insurance Supervision Commission (CSA), insurers, reinsurers and brokers now have a detailed rulebook: there is no longer any excuse for box-ticking compliance.

1. Applicable texts and supervisory authority

The foundation is Law No. 05-01 of 6 February 2005 on the prevention of and fight against money laundering and terrorist financing, extensively amended by Law No. 23-01 of 7 February 2023 and supplemented by Law No. 25-10 of 24 July 2025. Its Article 10 bis 3 designates the insurance supervisory authority, the Insurance Supervision Commission, as the supervisor of insurance companies, insurance brokers and factoring companies. For an overview of the reform, read our analysis of Law 23-01 on money laundering in Algeria.

The key sector text is CSA Regulation No. 01 of 6 November 2024, adopted after the Commission's deliberation of 23 October 2024. It sets out the obligations to prevent and combat money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction that apply to insurance and/or reinsurance companies and licensed insurance brokers. It is organised in nine chapters, from the risk-based approach through to sanctions.

Suspicious transaction reports are sent to the Financial Intelligence Processing Unit (CTRF), which reports to the Ministry of Finance.

2. Key obligations

Risk classification

The regulation requires a documented risk assessment proportionate to the nature, size and scope of the business. It covers clients, countries and geographic areas, products, services, transactions and distribution channels, taking the national risk assessment into account. It is updated periodically, circulated internally and provided to the CSA. Any new product, practice or technology, including remote onboarding, must be risk-assessed before launch. The resulting policies and procedures are approved by senior management: enhanced measures for higher risks, simplified measures only where low risk has been demonstrated.

Customer due diligence and beneficial owners

Due diligence applies when a business relationship is established, whenever there is a suspicion regardless of the amount, and whenever there is doubt about identification data. Natural persons are identified with a valid official document bearing a photograph; legal entities with their articles of association, proof of registration, actual address and directors' powers. A beneficial owner includes any natural person holding directly or indirectly 20% or more of the capital or voting rights; failing that, the person exercising control and, as a last resort, the legal representative. The beneficial ownership register kept by the CNRC helps cross-check this information.

Two points are specific to the sector. First, beneficiaries of life insurance and investment-linked policies, whether designated by name or by category, must be identified and verified at the latest at the time of payout. Second, politically exposed persons (PEPs), their family members and close associates require senior management approval before onboarding, establishing the source of funds and enhanced monitoring. If the beneficiary of a life policy is a PEP, senior management is informed before payment.

Suspicious transaction reporting to the CTRF

Any suspicious transaction is reported to the CTRF, even if it has already been executed or cannot be suspended, and any new information is passed on without delay. Reports are covered by professional secrecy and must never be disclosed to the client. Where due diligence cannot be completed, the reporting entity does not enter into the relationship or carry out the transaction; for an existing client, it ends the relationship and considers filing a report. If pursuing due diligence would tip off the client, it stops and files a report.

Asset freezing and targeted financial sanctions

The regulation requires immediate implementation of UN Security Council resolutions: freezing of assets and prohibition of any relationship or transaction with designated persons, using electronic screening systems. In practice, screening should cover policyholders, insured persons, beneficiaries and third-party payers. Relationships with high-risk countries designated by the CTRF call for enhanced due diligence.

Record keeping

Due diligence records, books of account and correspondence are kept for at least five years after the end of the relationship or the date of the occasional transaction; transaction documents for at least five years after execution, so that transactions can be reconstructed. You must be able to answer authorities' requests without delay.

Training and internal organisation

The AML/CFT programme is an integral part of internal control. It relies on a senior manager at executive management level responsible for compliance and acting as the main contact person for the CTRF, with independence and access to records; an independent audit function; demanding recruitment procedures; and ongoing training. Procedures are communicated to all staff, who can report a suspicious transaction to the compliance officer. To structure this role, see our guide to the compliance function in Algeria.

3. Sector-specific typologies and red flags

• a savings or capitalisation policy taken out and then surrendered early, with the client accepting the penalties without discussion;
• large premiums paid in cash, or split into smaller payments to stay unnoticed, out of line with declared income;
• premiums paid by a third party with no apparent link to the policyholder or the insured;
• designation or change of beneficiary in favour of a person with no identifiable family or business link, especially shortly before a surrender or a claim;
• repeated claims or schemes in which the payout is used to justify the origin of funds;
• a client reluctant to provide documents, an opaque ownership structure or the use of nominees;
• an introducer or intermediary concentrating unusual business, or a client connected to a high-risk country.

4. Common mistakes

In insurance companies and brokerage firms, we see recurring weaknesses, often rooted in the idea that insurance is a "low-exposure" sector.

• A generic risk map, copied from a banking template, that ignores the specifics of life, property and casualty or transport lines and of distribution channels.
• KYC limited to the policyholder: the insured, the life policy beneficiary and the third-party payer are neither identified nor screened.
• A distribution network outside the framework: agents and partners collect documents without procedures or training, and the insurer does not check their quality.
• Confusing insurance fraud with money laundering: suspicious files are handled as fraud cases, without considering whether a report to the CTRF is required.
• A compliance officer without authority, positioned too low and without full access to policy and claims management systems.
• One-off sanctions screening, carried out at onboarding but never re-run when lists are updated.

5. How Hodemia Consulting supports insurance companies and brokers

Fayçal Lounes, with nearly twenty years of regulatory compliance experience in Europe, the United States and the Middle East, supports insurers and intermediaries through:

• Compliance diagnostic (2 to 4 weeks): a gap analysis between your practices and CSA Regulation No. 01, with a prioritised action plan. Learn more in our article on the compliance diagnostic.
• AML/CFT programme set-up and KYC remediation: risk mapping by line of business and channel, due diligence procedures, handling of life policy beneficiaries, sanctions screening, CTRF reporting workflow.
• Compliance & Ethics training (1 day) for underwriting and claims teams and distribution networks. See our training courses.
• Leadership & Compliance seminar (2 days) for executives and board members who approve the AML/CFT policy.

To discuss your situation, get in touch. For an overview of the framework, also read our guide to AML/CFT compliance in Algeria.

Conclusion: using the CSA regulation as a risk management lever

The AML/CFT obligations for insurance companies and brokers are now precise: a documented risk assessment, identification of the client, the beneficial owner and the policy beneficiary, enhanced due diligence for PEPs, reporting to the CTRF, immediate implementation of UN sanctions and record keeping for at least five years. Leaving the grey list does not reduce any of these requirements; it shifts attention to proof that they are applied. Players who invest now in procedures tailored to their products, a trained network and committed governance will be ready for CSA inspections and for the next FATF evaluation.

Fayçal Lounes

Founder of Hodemia Consulting

Nearly 20 years of international experience in regulatory compliance, risk and governance (EY in Luxembourg, San Francisco and London; Director, Regulatory & Compliance Services at KPMG Middle East). Certified coach, trainer and academic.