Download the AMLR Reality Check to assess where your institution stands.
Trusted by leading financial institutions across Europe
Key facts:
Only around 30% of European financial institutions expect to be AMLR-compliant by July 2027, and insurers are no exception. According to PwC’s EMEA AML Survey 2024, fewer than three in ten organizations have launched a company-wide implementation strategy.
The challenge is not understanding the rules. Most compliance teams are well aware of what AMLR requires. The difficulty lies in execution: building scalable processes, maintaining consistent data quality, and documenting decisions comprehensively and continuously, rather than only at specific reporting dates. The pressure is increasing as well. AMLA will have the authority to impose significant sanctions for non-compliance, and insurers are explicitly included among the obliged entities under AMLR.
For insurers, an additional challenge is that AMLR cannot be considered in isolation. New pension products and digital onboarding models expected from January 2027 will drive a significant increase in digitally acquired customers, placing substantial pressure on KYC processes that are difficult to scale manually.
“In our experience, this is where the largest implementation gaps become visible. Many insurers have policies and rulebooks in place, but lack scalable, automated processes that can meet AMLR requirements on an ongoing basis,” says René Blaschke, Managing Director, Financial Crime Prevention and Compliance Solutions at cleversoft.
Keep reading for the five areas insurers need to act on now
Strengthen Governance and Oversight of Intermediaries
Even when onboarding activities are outsourced to brokers or intermediaries, regulatory accountability remains with the insurer.
Governance frameworks must provide clear oversight, monitoring capabilities, and intervention rights across delegated processes. Preparing only for occasional inspections will no longer be sufficient. Supervisors will expect continuous, readily accessible evidence of compliance for all outsourced activities.
Seamlessly Integrate CDD into Digital Onboarding
Customer Due Diligence (CDD) will become one of the primary operational bottlenecks under AMLR.
CDD processes must be seamlessly embedded into digital application and onboarding journeys. Digital identity verification and validation services (ID&V) need to operate in the background, enabling fast and compliant customer checks without disrupting the customer experience.
Understanding the rules alone is no longer enough. Insurers must close the execution gap through end-to-end automated workflows that connect onboarding, verification, risk assessment, and documentation.
Focus on Ultimate Beneficial Ownership (UBO)
The identification of Ultimate Beneficial Owners (UBOs) is particularly important in the context of occupational pension schemes.
Insurers must be able to demonstrate which corporate entities receive pension-related products and who ultimately owns or controls those organizations. Complex ownership structures increase the need for transparency, ongoing monitoring, and comprehensive documentation.
Organizations that continue to manage UBO identification manually and fail to systematically track ownership changes risk creating documentation gaps that may not satisfy increasingly demanding regulatory expectations.
Manage Screening and Overcompliance Risks
Insurers must design intelligent screening processes for adverse media checks, politically exposed persons (PEPs), sanctions screening, and related controls to avoid unintentionally excluding legitimate customers.
René Blaschke, Managing Director, Financial Crime Prevention and Compliance Solutions at cleversoft, explains:
“Overcompliance is one of the most underestimated risks in financial crime prevention. Highly restrictive, non-individualized decisions may reduce risk on paper, but they also limit business opportunities. Applying a risk-based approach with clearly defined and institution-specific risk agreements creates a much healthier ecosystem.”
A balanced, risk-based approach is therefore essential to protecting both compliance objectives and customer acquisition.
Improve Reporting and Audit Readiness
Supervisory authorities will increasingly expect every decision to be fully documented and traceable, including decisions made by brokers or intermediaries acting on behalf of insurers.
Organizations must be able to provide a complete digital audit trail covering customer onboarding, risk assessments, approvals, and ongoing monitoring activities.
Transparent records must be available within hours or days, not weeks.
Conclusion
Compliance under AMLR is evolving into a technology-enabled operating model. Institutions that take a structured approach now will be in a significantly stronger position when facing regulatory scrutiny. The cleversoft AMLR Reality Check provides a structured framework for assessing current readiness and systematically identifying compliance gaps before they become supervisory issues.