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IRDAI Fraud Monitoring Framework

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IRDAI Fraud Monitoring Framework

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ani_ju_it940
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© © All Rights Reserved
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Insurance Regulatory and Development Authority of India

(Insurance Fraud Monitoring Framework) Guidelines, 2024

In exercise of power enshrined under Section 34 of Insurance Act, 1938, Section 14(1)
of Insurance Regulatory and Development Authority Act 1999, Regulation 12 of the
Insurance Regulatory and Development Authority of India (Corporate Governance for
Insurers) Regulations, 2024 read with Master Circular on Corporate Governance for
Insurers, 2024, these Guidelines are issued to provide regulatory framework on
measures to be taken by Insurers and Distribution Channels to address and manage
risks emanating from fraud.

1. Short Title, Applicability and Commencement

1.1. These Guidelines may be called the Insurance Regulatory and Development
Authority of India (Insurance Fraud Monitoring Framework) Guidelines, 2024
1.2. These guidelines shall be applicable to all insurers and distribution channels
unless otherwise specified
1.3. These guidelines shall come into force from XXXXXXXXXXXXXX

2. Objective

To establish a comprehensive framework to identify, assess, and mitigate fraud risks


effectively across the insurance industry. This includes setting clear standards for
fraud detection and prevention, ensuring robust internal controls, and promoting
transparency in reporting and investigations. The guidelines aim to enhance the
sector’s resilience against fraud, foster a culture of integrity, protect policyholders'
interests, safeguard financial stability and maintain public trust.

3. Definitions
3.1. “Insurance Fraud” shall mean an act or omission intended to gain advantage
through dishonest or unlawful means for a party committing the fraud or for other
related parties; including but not limited to:
 Misappropriating assets;

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 Deliberately misrepresenting, concealing or not disclosing one or more material
facts relevant to the financial decision, transaction or perception of the parties
to contract of insurance;
 Abusing responsibility, position of trust or a fiduciary relationship.

3.2 Red Flag Indicator (RFI) means a possible warning sign, that points to a potential
fraud and may require further investigation or analysis of a fact, event, statement,
or claim, either alone or with other indicators.

3.3 Cyber or New Age Fraud means fraud carried out using digital or new age
technologies by any person with malicious intent by exploiting vulnerabilities in
systems, processes or people, resulting into insurance fraud, thereby posing
significant risks to the security and integrity of data, systems, processes, financial
transactions, and customer trust.

3.4 Distribution Channels means the distribution channels as defined under para 7 (8)
of IRDAI (Protection of Policyholders’ Interests and Allied Matters of Insurers)
Regulations, 2024.

3.5 Words and expressions used and not defined in these guidelines but defined in the
Insurance Act, 1938 (4 of 1938), Insurance Regulatory and Development Authority
Act, 1999 (41 of 1999) shall have the meanings respectively assigned to them in
those Acts, Rules, Regulations, Guidelines issued under those Acts, as the case
may be.

4. Classification of Frauds
4.1. Fraud comes in many forms and can manifest in various ways. It may be a plain
opportunistic act committed by a single individual, such as misrepresenting policy
features, falsifying documents, submitting false claims or siphoning of money.
Alternatively, it can be a sophisticated and elaborate scheme involving a large
number of people, possibly including employees of the insurer / distribution
channel and/or external parties. These complex operations often involve
coordinated efforts to deceive and exploit the insurance system, making detection
and prevention significantly more challenging. Whether simple or complex, fraud
poses a serious threat to the integrity and financial stability of the insurance

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industry. Understanding the varied nature of fraud is essential to effectively
combat it.
4.2. Fraud may be broadly classified into the following categories:
4.2.1. Internal Fraud: Fraud against the insurer, policyholders, customers or
beneficiaries by internal staff, including employees, senior management,
or board members, either alone or in collusion with others, with an intent
to defraud or deceive. It may, inter alia include misappropriating funds or
assets, theft of official data, privileged abuse / unauthorized privilege
access to critical assets, forgery or alteration of documents, colluding with
fraudulent claimants and concealment of fraudulent activities.
4.2.2. Distribution Channel Fraud: Fraud against the insurer, policyholders,
customers or beneficiaries by distribution channels, either alone or in
collusion with others, with an intent to defraud or deceive. It may, inter alia
include misrepresentation of policy features, premium siphoning and
embezzlement or withholding premiums, forgery of documents and
records, fabrication / falsification of information, documents and records,
willful and dishonest non-disclosure/concealment of material facts,
impersonation and collusion, inflation of claims and insuring or attempting
to insure non-existent persons, offering insurance from fake entities
through online and digital mode.
4.2.3. Policyholder Fraud and/or Claims Fraud: Fraud against the insurer,
by a person either alone or in collusion with others, in obtaining coverage
or payment during the purchase, servicing, surrender, or claim of an
insurance policy, with an intent to defraud or deceive. It may, inter alia
include, material misrepresentation and non-disclosure, fabricating
documents and records/signature, forgery and impersonation.
4.2.4. External Fraud: Fraud, other than Internal fraud, distribution channels
Fraud and Policyholder and/or Claims Fraud, against the insurer, by
external parties’ / service providers / vendors etc. It may, inter alia include
creating fake reports to support fraudulent claims, premium siphoning and
embezzlement, gaining unauthorized access to insurer’s resources,
inflating repair costs or billing for services not rendered after an insured
event, performing unnecessary medical procedures to bill insurers and
selling fake insurance policies or coverage.
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5. Risk Governance Framework

It is imperative to establish a structured and proactive approach for managing fraud


risk. Robust policies and procedures must be in place to identify potential fraud early,
respond swiftly to fraudulent activities, implement effective controls, and ensure
ongoing monitoring and review to minimize financial losses and reputational damage.

The Fraud Risk Governance Framework serves as an essential supporting structure


by which the board ensures accountability and transparency in managing fraud risk. It
enhances the insurer's ability to safeguard assets, maintain regulatory compliance,
and uphold trust among policyholders and stakeholders.

It is also necessary to have in place a well-documented policy to effectively implement


fraud risk management strategy in order to proactively address potential fraud, and
support the organization's long-term stability and success.

5.1. The monitoring and risk management of fraud shall be owned by Chairperson and
Managing Directors/Chief Executive Officers (CMD/CEOs), Risk Management
Committee and Audit Committee of the Board of the insurer.
5.2. Every insurer shall have in place appropriate fraud risk governance framework to
deter, prevent, detect, monitor and mitigate insurance frauds. The governance
framework shall include:
5.3. Anti-Fraud Policy
5.3.1. Insurer shall put in place a Board approved Anti-Fraud Policy which shall
include the procedures, processes and safeguards to be built in by the
Insurer to deter, prevent, detect, monitor, investigate, and report fraud.
Such policy shall target for zero tolerance for fraud and shall:

a) consider its business size and risk profile, unique nature, scale,
complexity, overall business strategy, products, distributions channels,
technology infrastructure, etc.
b) establish essential checks and controls to ensure early identification
and mitigation of fraud risks
c) establish suitable mechanism including nodal point(s) / designate
officer(s) for reporting incidents of fraud to Law Enforcement Agencies

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(LEA), proper coordination to meet the requirements of the LEAs and
follow up with the LEAs and/or court for final disposal of fraud cases.
d) establish appropriate mechanism for disciplinary action in case of fraud
or non-compliance to the fraud risk governance framework
e) include adequate fraud detection measures in case online platforms
are used for solicitation, servicing and claim settlement of insurance
policies
f) ensure that the appropriate and adequate resources are provided to
the Fraud Monitoring Unit to carry out its functions effectively.
g) ensure that people alleged/involved of fraud shall not continue in
sensitive posts
h) define responsibilities, delegation of authorities for all relevant
functions and levels to prevent, detect, monitor, investigate, and report
fraud.
i) Consider other relevant areas as outlined in Annexure 1.

5.3.2. The insurer shall review the Anti-Fraud Policy regularly, at least annually,
based on risk exposure, operational experience and emerging trends.

5.4. Fraud Monitoring Committee: Every insurer shall establish a Fraud Monitoring
Committee (FMC) to oversee fraud deterrence, prevention, detection, monitoring,
investigation, and reporting activities.
5.4.1. Structure of Fraud Monitoring Committee: The FMC shall be headed by
a KMP and shall include senior representatives from relevant departments,
such as underwriting, claims, legal or any other department as the committee
may deem necessary. The FMC may establish subcommittees or task forces
for its effective functioning.
5.4.2. Functions of Fraud Monitoring Committee: The functions of the FMC shall
inter alia include:
a) Recommending appropriate measures on fraud risk management to
various functions and regularly update based on experiences.
b) facilitating effective management, oversight and execution of the insurer’s
fraud risk management and control processes

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c) ensure prompt responses to instances or suspicions of fraud relating to
various departments
d) effective implementation of fraud risk governance framework across all
applicable functions of the insurer, service providers, vendors and
distribution channels as applicable.
e) taking appropriate actions against the fraud perpetrators (internal /
distribution channels/external fraud as applicable).
f) monitoring and evaluating the insurer’s fraud prevention efforts to identify
areas for improvement and adaptation.
g) conduct of customer awareness programs and periodic training programs
for employees and distribution channels at all levels to educate them
about fraud risks and preventive measures.

5.4.3. Reporting Requirements: The FMC shall submit quarterly reports to


the RMC on its activities, findings, and recommendations including
analysis on the number of fraud cases detected, investigated, and
prevented, as well as the financial impact of fraud on the insurer. FMC
shall submit report of the annual review of the frauds before the Board of
Directors through RMC. In case of all internal frauds, FMC shall also report
to the Audit Committee, in addition to the RMC.

5.5. Fraud Monitoring Unit: Every insurer shall establish an independent Fraud
Monitoring Unit (FMU), separate from internal audit, which will support FMC in
discharging its functions and shall be responsible for implementing measures for
fraud deterrence, prevention, detection, monitoring, investigation, and reporting.

The functions of the FMU, in addition to supporting FMC, shall inter alia include:

a) effective implementation of measures suggested by FMC


b) monitoring insurance claims, policy applications, and other transactions, as
appropriate, for RFIs or signs of fraudulent activity and investigation of RFIs.

6|Page
c) investigations, evidence gathering, and collaboration with relevant
departments for investigation. Conflicts of interest shall be identified and
avoided throughout the investigation process.
d) timely reporting of identified fraud cases to FMC as per the established
procedure of the insurer
e) maintaining transactional-wise details of each and every fraud including
action taken
f) collaborating with industry peers / bodies, law enforcement agencies and
regulatory bodies to pursue cases of fraud and share information /
intelligence on known fraud schemes and perpetrators.

5.6. Risk Identification and Measurement: Insurers shall put in place appropriate
measures to identify and assess fraud risks. It shall inter alia include:
5.6.1. Annual Comprehensive Risk Assessment: Insurers shall conduct and
submit to Board, an Annual Comprehensive Risk Assessment to identify
potential vulnerabilities across business lines and activities for fraud, using
past experiences, emerging trends & Red Flag Indicators (RFIs), etc.
5.6.2. Red Flag Indicators for fraud detection: Based on the lines of
business, activities, past experience, trends etc, Insurers shall identify Red
Flag Indicators (RFIs), as applicable, for detection of frauds and
incorporate them appropriately in their operations. Such RFIs shall be
reviewed regularly for their continued relevance and effectiveness in
detecting fraud. For examples of RFIs, please refer to
https://www.iaisweb.org/uploads/2022/01/Application_paper_on_fraud_in
_insurance.pdf.pdf

5.7. Risk Control and mitigation: In order to ensure the fraud risks identified as part
of the Annual Comprehensive Risk Assessment are mitigated, Insurers shall have
in place appropriate measures to deter, prevent, monitor, investigate, and report
fraud with respect to the following:
5.7.1. Internal Fraud: To mitigate internal fraud, insurers shall implement
measures such as prudent HR practices (background checks and
reference verification during recruitment, job rotation policies), regular

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training to employees on fraud awareness, secure and confidential whistle-
blower mechanism for reporting frauds, segregation of duties, maker
checker process and strict access controls with respect to critical
transactions and sensitive systems, etc.
5.7.2. Distribution Channel Fraud: To mitigate Distribution Channel fraud,
every insurer shall adopt measures such as fit and proper standards for
distribution channels including background checks for any adverse
records, adherence to insurer’s fraud management controls as applicable,
documented procedures for change in policyholder’s personal information,
robust system for tracking and analyzing customer complaints against
distribution channels, scrutiny of distribution channels in case of high policy
turnover rates or unusual patterns of policy cancellations and reissuances,
regular reconciliation between intermediary records with insurer database,
etc.
5.7.3. Policyholders or Claims Fraud: To mitigate policyholder or claims
fraud, insurers shall implement measures such as robust client acceptance
policy, embedding safeguards throughout the product life cycle, educating
policyholders and the general public about the consequences of insurance
fraud, robust underwriting processes to assess the risk profile of
policyholders accurately, appropriate controls throughout the claims
management process to detect and prevent fraudulent claims, deploying
advanced technologies to identify patterns and anomalies indicative of
fraudulent behaviour, etc.
5.7.4. External Fraud: To mitigate external fraud insurers shall implement,
among others, measures such as periodic due diligence on vendors’ /
service providers, regular audit and review of the performance of vendors
/ service providers in implementing contractual clauses and service level
agreements, etc.

6. Risk Monitoring and Review


6.1. Every insurer shall establish and maintain an “Incident Database” of relevant
parties who have been convicted of fraud or have attempted to defraud the insurer
or policyholder.
8|Page
6.2. An insurer shall:
a) monitor the performance and trend of business brought in by distribution
channels.
b) carry out periodic fraud-sensitive audits to ensure compliance with its
policies and procedures regarding insurance fraud risk.
c) continuously monitor vendor activities to ensure compliance with fraud
prevention measures and contractual obligations.
d) monitor customer grievances, complaints, etc. to detect and prevent frauds.

7. Cyber or New Age Fraud


7.1. Cyber fraud can have far-reaching consequences, including identity
impersonation, financial frauds, reputational damage etc. Personal information
such as KYC details, financial details, and medical records are highly coveted by
cybercriminals, who exploit vulnerabilities in security defences to gain
unauthorized access to these sensitive data available with insurers or distribution
channels. In order to prevent such frauds, Insurer shall:
7.1.1. establish robust cybersecurity framework and implement appropriate
controls to strengthen their defences against evolving cyber frauds or
threats.
7.1.2. ensure that the systems or processes used for fraud risk identification,
detection, prevention, mitigation, monitoring such as Incident Database,
measures to verify customer information before accepting proposal to
prevent identity frauds, risk posed by different distribution channels,
enhanced verification mechanisms for certain areas with high incidence of
frauds, access rights to employees or vendors as per principle of least
privilege etc. are continuously monitored and strengthened.
7.1.3. deploy specialised and competent team with relevant risk or
technological expertise for managing cyber fraud risks emanating from
various lines of insurance business.

8. Insurance Information Bureau (IIB)


8.1. Data analytics plays a crucial role today in enabling organisations to detect,
predict, and mitigate frauds. By leveraging advanced techniques organisations
can stay ahead of fraud risks and protect their assets.
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8.2. In order to ensure that the data available with insurers is effectively utilized to
prevent frauds in insurance sector, an appropriate Fraud Monitoring Technological
Framework cutting across all line of insurance business at IIB shall be utilized. As
insurers are both data providers to IIB and beneficiaries of the aforementioned
framework, all insurers shall participate in IIB’s fraud monitoring mechanism to
help the industry combat fraud and protect policyholders and all stakeholders.
8.3. The common platform at IIB containing the industry-wide database on suspected
and reported fraudulent activities within the insurance industry shall facilitate
timely threat intelligence sharing across insurance sector. For the platform to be
effective, suitable mechanism for identifying policyholders irrespective of insurer,
such as a unique identifier, shall be adopted.
8.4. IIB shall maintain a caution repository concerning blacklisted agents, distribution
channels, hospitals, TPAs, etc. in order to safeguard the integrity of the insurance
market by preventing the involvement of those with a record of fraudulent
activities.

9. Framework for Reinsurance


9.1. Reinsurers can reduce their exposure to fraudulent claims from ceding insurers
and reinsurance intermediaries by understanding the fraud risk management
systems the counterparties have in place. Accordingly, these guidelines apply
mutatis mutandis in case of Reinsurers.
9.2. The Insurers shall accord special attention to reinsurance transactions in fraud
monitoring activities.
9.2.1. Insurer shall put in place systems and processes to verify the authenticity
of all reinsurance transactions, especially those involving multiple
intermediaries or cross-border placements. Insurer shall take extra care
with transactions involving intermediaries that are not part of their regular
list or when the cover is obtained from reinsurers whose credit rating is
below the benchmark or does not meet the acceptance limits specified in
their reinsurance policy.
9.2.2. Insurer shall mandatorily seek direct confirmation from the reinsurer
immediately after placement or premium remittance, verifying the
acceptance of terms and risks as outlined in the slip received from any
intermediary. Where placement is through a distribution channel, insurer
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shall also obtain direct confirmation from the reinsurer on receipt of the
premium.
9.3. Robust controls, verification processes, and periodic audits shall be conducted to
mitigate risks associated with reinsurance fraud.

10. Framework for Distribution Channels

Distribution channels are integral to the insurance business, serving as key facilitators
between insurers and policyholders. They handle a range of responsibilities, from
distributing and servicing of insurance products to managing client relationships,
making them a significant stakeholder in fraud risk management. To ensure a
comprehensive approach to fraud prevention, it is essential that distribution channels
also establish an appropriate fraud risk monitoring framework commensurate with their
business size and risk profile.

10.1 Intermediary and Insurance Intermediary (except for individuals)


10.1.1 As a part of corporate governance, Intermediaries and Insurance
Intermediaries shall recognise and understand fraud risk to their
organization, including potential types and impact of frauds and take steps
to minimize their vulnerability to Frauds.
10.1.2 Intermediaries and Insurance Intermediaries shall put in place internal
policies, procedures and controls to deter, prevent, detect, report and
remedy frauds. Types of frauds mentioned under para 4 and red flag
indicators shall be taken into account, as applicable, while forming such
policies. Internal policies shall at the minimum cover:

 Education, awareness and training to employees


 Internal reporting structure for frauds
 Procedure for reporting Frauds to Law Enforcement Agencies (LEAs),
proper coordination to meet the requirements of the LEAs and follow up
with LEAs and/or court for final disposal of fraud cases
 Due diligence procedures for appointing employees / sales persons
 Whistle Blower Policy
 Internal procedures to detect, prevent and mitigate frauds

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 Investigation
10.1.3 Whenever there is a suspicion of Fraud which may also impact the
Insurer, the same shall be brought to the notice of Insurer.
10.1.4 Responsibility for ensuring that Intermediaries and insurance
intermediaries have adequate fraud risk management ultimately lies with
the Board and Senior Management of the intermediary.

10.2 Distribution Channels other than Intermediary and Insurance Intermediary:


10.2.1 Distribution Channels (other than Intermediary and Insurance Intermediary)
shall comply with the insurer’s anti-fraud policies, procedures and controls.
10.2.2 Whenever there is a suspicion of Fraud which may also impact the Insurer, the
same shall be brought to the notice of Insurer.

11 Training, Education and Awareness

Training, education, and awareness are vital for strengthening fraud prevention efforts.

11.1 Insurers shall conduct regular fraud awareness programs to educate


policyholders and the general public about the risk of fraud and offer advice on
how to prevent and protect against it.
11.2 Insurers shall conduct regular training programs for employees including board
members and senior management, intermediaries, and agents on fraud risk
management. The type of training shall correspond with the business process in
which the person is engaged.

12 Reporting
12.1 Insurers shall report incidents of fraud to Law Enforcement Agencies and/or other
relevant agencies subject to applicable laws
12.2 Insurers shall file annual returns with Authority in forms FMR-1 placed in
Annexure III within 30 days of close of the financial year.
12.3 In the event of fraud committed by distribution channels registered by IRDAI, the
insurer shall promptly escalate and report the matter to IRDAI without delay.

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Annexures
Annexure-I - Anti-Fraud Policy
1. Introduction
a. Anti-Fraud Mission Statement
A mission statement will indicate the insurer’s level of tolerance to fraud and
provide direction to the anti-fraud plan.
b. Anti-Fraud Goals
Anti-fraud goals can indicate the insurer’s quantitative risk tolerance limits on fraud
and its priorities (Deterrence, Loss minimization, Objective claims handling, etc)
2. Definitions
This shall include:
a. ‘fraudulent insurance act / suspected insurance fraud / attempted insurance
fraud’, classification of fraud and other relevant terms as defined in these
guidelines
b. other definitions of key terms used in the insurer’s Anti-Fraud Plan

3. Prevention, Detection and Investigation of Insurance Fraud


This shall include:
a. a description of the insurer’s fraud prevention, detection, and investigation
procedures for each category of fraud (Internal Fraud, Intermediary Fraud,
Policyholder / Claims Fraud and External Fraud)
b. a detailed list with brief explanations of the red flags / fraud indicators for each
line of business that the insurer uses to detect instances or suspicion of fraud
c. A description of the insurer's fraud investigation process, including evidence
collection, documentation methods for suspected frauds, internal timelines
from fraud detection to investigation and report submission
d. a description of the procedures for hiring / contracting external fraud
investigators including required qualification, experience, etc
e. a description of the insurer’s procedures for reporting insurance fraud to
appropriate law enforcement agencies including the official(s) responsible to
report fraud and timelines for reporting, following up, etc.
f. a description of the insurer’s due diligence procedures while appointing / on
boarding / hiring personnel (management and staff)/ insurance agent/
intermediary/ third party service provider
g. a description of the insurer’s fraud detection methodology, technology and
systems including automated red flags, predictive modelling etc
h. a description of audit or review process to identify "missed" insurance fraud
detection opportunities
i. a description of the insurer’s whistle blower protection policy

4. Education and Awareness


This shall include:

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a. A description of the insurer’s external fraud awareness or outreach program(s)
geared towards applicants, policy holders and members of the general public.
b. A description of the insurer’s internal awareness/antifraud education and
training initiatives of any personnel involved in antifraud related efforts
including employees and distribution channels. The description shall include
topics covered, method of training and exam / quiz, frequency and minimum
number of training hours provided, etc.
5. Primary Contact
Contact information of the official(s) responsible for oversight and implementation
of the Insurer’s anti-fraud plan

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Annexure II

Fraud Monitoring Reports

FMR – 1
Fraud Monitoring Report

Name of the Insurer:

Report for the year ending

Part I

Frauds Outstanding- Business segment wise :

Sl. Category Unresolved Cases at New cases Cases closed Unresolved


No. of Fraud the beginning of the detected during the during the year Cases at the
(LoB wise) year year end of the year
No. Amount No. Amount No. Amount No. Amount
involved (` involved (` involved (` involved
lakh) lakh) lakh) (` lakh)
Internal
Fraud
Distributio
n Channel
Fraud
Policyhold
er and/or
Claims
Fraud
External
Fraud
Total
*Irrespective of the category of fraud, details of Cyber / New Age Fraud shall be reported
separately containing brief description / details like nature of data used to carry out fraud,
modus operandi, financial impact etc.

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Part II – Age-wise analysis of unresolved cases
Sl. Unresolved Cases at No. Amount involved (`
No. the end of the year lakh)
(age-wise)
1 30-60 days
2 60 – 180 days
3 180 – 360 days
4 More than 360 days
Total

Part III
Cases Reported to Law Enforcement Agencies
Sl. Description Unresolved New cases Cases closed Unresolved
No. Cases at the reported during during the cases at
beginning of the year year the end of
the year the year
No. ` lakh No. ` lakh No. ` lakh No. `
lakh
Cases reported to Police
Cases reported to CBI
Cases reported to Other
agencies (specify)
Total
* Business segments shall be as indicated under IRDAI (Actuarial, Finance and
Investment Functions of Insurers) Regulations 2024

CERTIFICATION
Certified that the details given above are correct and complete to the best of my
knowledge and belief and nothing has been concealed or suppressed.

16 | P a g e
Date: Signed/-
Place: Name of the Chief Executive Officer of the
Insurer

# Closure of Fraud Cases:

For reporting purposes, only in the following instances of fraud cases can be
considered as closed:

1. The fraud cases pending with CBI/Police/Court are finally disposed of.
2. The examination of staff accountability has been completed
3. The amount of fraud has been recovered or written off.
4. The insurer has reviewed the systems and procedures, identified the causative
factors and plugged the lacunae and the fact of which has been taken note of
by the appropriate authority of the insurer (Board / Audit Committee of the
Board)
5. Insurers are allowed, for limited statistical / reporting purposes, to close those
fraud cases, where:

a. The investigation is on or challan/ charge sheet not filed in the Court for
more than three years from the date of filing of First Information Report (FIR)
by the CBI/Police, or
b. The trial in the courts, after filing of charge sheet / challan by CBI / Police,
has not started, or is in progress.

Insurers shall also pursue vigorously with CBI for final disposal of pending fraud
cases especially where the insurers have completed the staff side action. Similarly,
insurers may vigorously follow up with the police authorities and/or court for final
disposal of fraud cases and / or court for final disposal of fraud cases.

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