Co-Ordinating and Managing a Corporate Insurance Mediation Directive (IMD) Compliance Programme

Ifeanyi Uyanneh, Legal Counsel - Compliance Director, Affinion International Limited, UK

The Insurance Mediation Directive (the ‘IMD’) was implemented across the European Union and European Economic Areas (‘Member States’) in order to remove restrictions on the freedom, and ability of insurance and reinsurance intermediaries (‘Intermediaries’) to operate throughout Member States. The IMD, which has now been fully implemented across Member States, required them to introduce legislation governing relationships between Intermediaries and their clients, as well as enhancing consumer protection in relation to insurance mediation. It should be noted that the European Commission (‘EC’) is currently undertaking a review of the provisions of the IMD with a view to improving their legal clarity and certainty . The objective of this article is to examine the challenges that are likely to be encountered by Intermediaries’ Legal and, or Compliance functions (‘Legal function’) in co-ordinating, and managing a European-wide corporate IMD compliance programme. This article will also consider practical approaches, and solutions that may be adopted to overcome these challenges.

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United Kingdom Compliance Insurance May 2010 Vol. 3, No. 11, Spring 2010

Ifeanyi Uyanneh

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Ifeanyi Uyanneh is a Solicitor, and Chartered Management Accountant and has been responsible for leading Affinion International’s corporate European compliance programme. Ifeanyi also advises on commercial and corporate legal matters. Before joining Affinion International, Ifeanyi worked in insurance and banking.

Affinion International Limited

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Affinion International Limited is the international arm of Affinion Group, Inc., a global provider of customer engagement and loyalty solutions that offer lifestyle and protection benefits and programs, to over 105,000,000 customers worldwide. Affinion Group, Inc. has over 35 years experience, with revenues of more than $1.3 billion, and has more than 5,500 marketing partners in a variety of industries including financial services, retail, travel, telecommunications and utilities.

United Kingdom Compliance Insurance May 2010 Vol. 3, No. 11, Spring 2010