CDD is the identification and verification of both the client and ultimate beneficiary including but not limited to continuous monitoring of the business relationship with the insurance institution.Insurance entities are not permitted to underwrite policies for unidentified persons or in fictitious names. Insurance institutions shall in respect of all customers/policyholders determine whether or not a customer/policyholder is acting on behalf of another person. Where the customer/policyholder is acting on behalf of another person, the institution shall take reasonable steps to obtain sufficient identification-data and to verify the identity of that other person.1,4.4 Insurance institutions shall take reasonable measures in respect of customers/policyholders that are legal persons or legal arrangements to: understand the ownership and control structure of such a customer; and        (b)        determine the natural persons that ultimately own or control the customer.The natural persons include those persons who exercise ultimate and effective control over the legal person or arrangement. Examples of types of measures needed to satisfactorily perform this function include:For companies - The natural persons are those who own the controlling interests and those who comprise the mind and management of the company; andFor trusts — The natural persons are the settler, the trustee and person exercising effective control over the trust and the beneficiaries.Where the customer or the owner of the controlling interest is a public company subject to regulatory disclosure requirements (i.e. a public company listed on a recognized stock exchange) it is not necessary' to identify and verify the identity of the shareholders of such a public company.