Bank accounts

Types of delegated authority this guidance is relevant to

  • Binding authority agreements 
  • Coverholder appointment agreements 
  • Service company agreements 
  • Delegated claims agreements 
  • Digital platform provider agreements

Key definitions

Trust account: A bank account managed by a trustee for the benefit of designated beneficiaries according to the terms of a trust.

Sweep account: A bank account arrangement that automatically transfers funds between linked accounts according to predefined rules 

Co-mingling Holding: Lloyd’s and non-Lloyd's monies in the same bank account.

Why guidance is needed

To ensure that insurer monies are appropriately protected, identifiable, traceable and recoverable, and that the handling complies with applicable legal, regulatory and contractual obligations.

For assistance updating the bank account details within Lloyd’s systems, please visit the ‘ATLAS how to guide’.  

Lloyd’s requirements

Premium Trust Deeds

Insurance monies received by third parties fall within the scope of the Premium Trust Deeds signed by all members at Lloyd’s and accordingly should be treated as trust assets, and form part of the Premium Trust Fund (PTF). Managing agents should therefore ensure that third parties, such coverholders and banks that hold PTF assets, hold those amounts in accordance with the requirements of the Premiums Trust Deed.

Segregation and Protection of Funds

Managing agents must be satisfied that insurer monies are protected from misuse, loss and insolvency risk, and that any co-mingling does not compromise their identification, traceability or recoverability.

Funds must be clearly identifiable, traceable and reconcilable to the relevant delegated arrangement. Managing agents must be satisfied that the coverholder's own funds are distinguishable from insurer and client monies and do not compromise their protection or recoverability.

Managing agents should determine which banking arrangements meet applicable legal, regulatory and contractual requirements and achieve the required outcomes in the relevant jurisdiction. Their assessment should reflect the nature, scale, complexity and risk of the delegated arrangement. Where basic controls are not available in the jurisdiction, alternative controls should be considered on a risk-based approach.

Payment Authorisation and Control

Managing agents must be satisfied that payment arrangements provide effective independent challenge or oversight so that no individual can exercise unchecked end-to-end control over initiating, authorising, processing and reconciling a transaction. Controls should be proportionate to the nature, scale, complexity and risk of the delegated arrangement.

Authorisation frameworks may include dual authorisation, independent payment approval, workflow controls, system-based segregation of responsibilities, transaction limits, post-payment review processes, or other measures that achieve equivalent outcomes. These are examples rather than prescribed controls; the managing agent should be able to explain how its chosen arrangement achieves the outcome.

Lloyd’s expectations of managing agents

Managing agents should determine the frequency and depth of ongoing oversight according to the risks presented by the delegated arrangement. Oversight should identify material changes, control weaknesses or emerging risks and result in timely challenge and remediation where the required outcomes are not being achieved.

Demonstrating Compliance

Managing agents should be able to evidence, proportionate to the nature, scale, complexity and risk of the delegated arrangement, that banking arrangements achieve the following outcomes:

  • Protect insurer monies.
  • Prevent unauthorised or inappropriate movement of funds.
  • Provide effective segregation of duties and independent oversight.
  • Maintain adequate records, audit trails and reconciliation processes.
  • Comply with applicable legal, regulatory and contractual requirements.
  • Support the managing agent's ability to oversee and challenge the handling of funds on an ongoing basis.

Sweep Accounts

Where sweep accounts are used, managing agents must be satisfied that they continue to achieve the outcomes of fund protection, identification, traceability and recoverability and comply with applicable legal, regulatory and contractual requirements. The nature and extent of oversight should reflect the additional risks created by the arrangement, and identified weaknesses should be addressed promptly. The assessment should cover the destination accounts and the protection of funds throughout the transfer and while held in those accounts.

Contractual Considerations

Managing agents should ensure that contracts of delegation clearly establish the outcomes and responsibilities applicable to the handling of monies. Where model contract wordings prescribe specific banking arrangements, these should remain consistent with the approved banking structure and should not create conflicting obligations. Where the entity receiving or holding monies differs from the entity delegated to, such as an appointed representative or principal, the contractual arrangements should make clear who is responsible for the funds and how the managing agent can oversee them.

Last reviewed 26/10/2026

Last updated 29/10/2026