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

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

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.