Screen the beneficiary at the moment the money leaves.

The person you pay is often the person you have never checked. EU, UK and US rules all bite at payout. DetectX® screens policyholders, beneficiaries and payees against sanctions, PEP lists and adverse media, from inception to the claim, and holds a higher-risk payout for senior management before it is released.

  • EU AMLR Articles 44 and 47
  • UK MLRs regulation 35
  • US OFAC and FinCEN

Illustrative DetectX® screens. Invented names and data.

What Regulators Require, Before the Money Moves

Every regime asks the same three questions: who is your customer, who stands behind them, and who receives the money.

Choose your market and sector to see the rules that apply to you.

Your sector

The FATF Recommendations are the standard more than 200 jurisdictions are assessed against. National rules build on them.

  1. Identify and verify the customer and the beneficial owner, understand the ownership and control structure of legal persons, and keep due diligence going for the whole relationship.

    Read FATF R.10

Last reviewed 4 November 2026 · A summary of the cited rules, not legal advice.

Most firms can prove who came in. Not who they’ve become since.

Onboarding tells you who a customer was on day one.

Tell us where you operate and what you do, then answer five questions. Each gap is shown against the rule that applies to you.

Where you operate

Your sector

  1. OngoingWhen a sanctions or PEP list changes, are existing customers and their beneficial owners screened again?

  2. OwnersAre the beneficial owners of corporate customers screened in their own right, not only the company?

  3. Adverse mediaDo you screen customers and their owners against adverse media as well as official lists?

  4. FraudDoes fraud detection run on payments alongside identity screening?

  5. Money outIs the counterparty screened before an outgoing payment is released?

The DetectX® Approach

Payout screening is the check of everyone who receives money under a policy, against sanctions lists, PEP lists and adverse media, before the payment is released.

DetectX®, from Prospero AG in Vaduz, Liechtenstein, screens every party from inception to payout, holds a higher-risk payout for sign-off, and records every decision with four-eyes review.

Everyone with a claim on the money. A policy has more people attached to it than the customer who signed it. Each party your policy record holds is screened in its own right, and corporate policyholders and beneficiaries bring their beneficial owners with them.

Policy LV-58214Every party, screened in its own rightSanctions, PEP lists and adverse media
PolicyholderAt inception and for the life of the policy
Insured personWhere different from the policyholder
BeneficiariesNamed, or designated by class
Beneficial ownersOf corporate policyholders and beneficiaries
AssigneesWhen the policy changes hands
PayeesIncluding third-party claimants

Key Benefits & Impact

Know who you are paying before you pay them.

Every party is screened, a risky payout waits for the right person, and every decision stays on the record.

Every Party

Every party screened, not only the policyholder.

Policyholders, insured persons, beneficiaries, assignees and payees are each screened against sanctions lists, PEP lists and your own lists.

Name Screening

Lists: sanctions, PEP and your own. Example data.

Payout Hold

A higher-risk payout waits for sign-off.

A PEP or sanctions match holds the release, and senior management is informed before the money moves, with the decision on file.

WorkflowsTo confirm: the payout hold

Released only after sign-off. Invented names and data.

Rescreening

Decades-old policies, checked today.

Every party is rescreened when a list updates, so a beneficiary listed years after the policy was written raises an alert.

Name ScreeningTo confirm: rescreening on list updates
Policy written14 years ago
List updateA beneficiary is listed
New alertSame queue, worked the same way
Adverse Media

Reputation, checked on the payee.

Adverse Media Search runs from the alert on the matched party and rates every article for risk and sentiment.

Adverse Media Search
Claims And Fraud

Claims checked for how they behave.

Fraud signals and screening results land in one case, so the analyst sees both before the claim is paid.

To confirm: Fraud Detection signals in the same case
Name ScreeningWho is being paid
Fraud DetectionHow the claim behaves
One caseOne analyst, one decision, one record
On The Record

Every payout decision, on file.

Who acted, when, on what evidence and why, with four-eyes sign-off, ready for the supervisor.

Workflows
Analyste.marti · evidence reviewed
Senior managementr.vogt · informed before payout
Four-eyes sign-offj.feldmann · payout released

Recorded · j.feldmann · 15:03 · “Second reviewer agrees with the evidence and the reason.”

Why DetectX®

Most insurers screen who comes in. DetectX® screens who gets paid.

  • Who is screenedThe policyholder, at inceptionPolicyholder, insured, beneficiaries, assignees and payeesName Screening
  • The beneficiaryNamed on file, looked at when the claim arrivesScreened when designated, and again at payoutName Screening
  • Checked again, not onceAt inception and renewalOn every list update, for the life of the policyName Screening
  • Higher risk at payoutAn email to a managerPayout held until senior management is informed and signs offWorkflows
  • ClaimsFraud and screening in separate toolsFraud signals and screening results in one case
  • ReputationA separate web searchAdverse media on the matched party, from the alertAdverse Media Search
  • On the recordNotes in a claim fileEvery decision recorded, with four-eyes sign-offAudit trail

The Audit Trail

Every payout decision, on the record.

From the moment a payout is requested to the moment it is released, every step is recorded: who acted, when, on what evidence and why. When a supervisor asks how a PEP beneficiary was paid, the answer is already on file.

Payout alert AL-PAYOUT-00418806, policy LV-58214 · invented example

  1. Payout requestedSystem

    Death benefit approved for payment. Policy LV-58214, two beneficiaries and the payee accounts are sent for screening: payouts are screened before release.

  2. Alert raisedSystem

    Beneficiary Andrei Novak, screened on name and date of birth: Match · 89, above the 85 threshold. Name, date of birth and nationality match a PEP list entry.

  3. Payout heldSystem

    An open alert on a payee pauses the release: payment of EUR 420,000 on hold. A payee with an open alert is not paid.

  4. Assignede.marti

    Role-based user rights decide who may claim the alert. The analyst holds the rights for payout alerts.

  5. Evidence reviewede.marti

    The list entry, the policy file and an adverse media search are checked. Confirmed: the same person, a serving deputy minister. Date of birth and nationality agree; no negative media.

  6. Senior management informedr.vogt

    The higher-risk payout is escalated with the findings and the proposed enhanced scrutiny. The Head of Compliance is informed before payout, as required before paying a PEP beneficiary.

  7. Four-eyes sign-offj.feldmann

    A second reviewer checks the disposition and its justification and agrees: approved, the payout is released, and the relationship stays under enhanced scrutiny.

Payout alerts share the AlertViewer, lists and audit trail with every DetectX® module, so a payout decision reads like any other on the record.

Payout Screening FAQs

What insurance compliance teams ask about beneficiaries and payouts.

Something we have not covered?Talk to our team

Payout screening is the check of everyone who receives money under a policy, such as beneficiaries, assignees and third-party claimants, against sanctions lists, PEP lists and adverse media before the payment is released. It covers the people an insurer may never have screened at inception.

Under Article 44 of Regulation (EU) 2024/1624, no later than the time of payout or the assignment of the policy. Where higher risk is identified, senior management must be informed before the proceeds are paid out. The Regulation applies from 10 July 2027.

As soon as beneficiaries of life and other investment-related policies are identified or designated, the insurer records the name of a named beneficiary, or obtains enough information on a beneficiary designated by class to identify them at payout. Identity is verified at the time of payout.

Regulation 35 of the MLRs 2017 requires a long-term insurer to take reasonable measures to determine whether a beneficiary, or a beneficiary's beneficial owner, is a PEP or a family member or close associate of one, before any payment or assignment. Senior management must be informed before a PEP beneficiary is paid.

Under OFAC's insurance guidance, block the policy or the relevant portion, report the blocking to OFAC within 10 business days, and obtain a specific licence from OFAC before paying any claim under it.

The beneficiary rules in AMLR Articles 44 and 47 and UK MLRs regulation 35 cover life and long-term policies, and FinCEN's insurance AML rule covers permanent life, annuities and products with cash value. Sanctions apply to every line: paying a claim to a listed person is prohibited in the EU, the UK and the US.

The insured person where different, every beneficiary, the beneficial owners of corporate policyholders and beneficiaries, assignees when a policy changes hands, and payees, including third-party claimants who were never your customer.

At inception, when a beneficiary is named or changed, in every recurring run against updated lists, at the claim and at payout. A new listing raises a fresh alert on the policy it affects.

No. DetectX® screens the parties, raises alerts and holds the release while an alert is open. Your analyst decides, senior management is informed where risk is higher, and a second reviewer signs off. Every step is recorded.

Each match is scored against a threshold you set, using phonetic, transliteration and fuzzy matching. A cleared false positive goes on the White List after four-eyes review and stops returning on later runs.

Prospero AG builds DetectX®, a financial crime compliance platform covering name screening, adverse media, transaction monitoring, client risk scoring and fraud detection. Prospero is based in Vaduz, Liechtenstein.

Payout Screening · DetectX®

See a payout screened before it is paid

A 30-minute review with a product specialist who knows your market's rules, on your own policy types.

Every party
Policyholders, beneficiaries, assignees and payees.
Held when it matters
Higher-risk payouts wait for sign-off.
On the record
Every decision, with who, when and why.