During a routine periodic KYC refresh of a policyholder and client of an insurance company,...

Investigate the changes of address and change of UBO and in the meantime decline payment and withdrawal instructions from the policy until completion of the investigation and next steps are agreed upon

Request the relationship manager set up a meeting with the policyholder to update their address and submit details of the new UBO in the name of good customer service

Investigate the changes of address and change of UBO and in the meantime freeze the client's policy

File a suspicious transaction report because the insurance company was not made aware of the business' change of UBO