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insurer asks which countries I trade with what do I provide

You usually specify countries based on actual trade activity

Usually, the insurer does not ask for every country to which you have ever sent an invoice, but rather the countries with which you conduct business on a structural basis: regular suppliers, regular customers, establishments. This is a client due diligence question, not a CSRD question — the insurer wants to know where the risk lies, not how sustainable the chain is. Sanctioned countries and countries with a high-risk profile carry more weight than a one-off order to a neighbouring country. If you are unsure whether an incidental transaction should be reported, look at what the portal itself identifies as the threshold (often a minimum amount or percentage of turnover) rather than setting your own threshold.

What you concretely provide depends on what the chain file already records: often a list of countries with turnover share or number of relations per country, linked to the establishments and possibly the banking relationships located there. If there is doubt about a country because a counterparty is established there, that quickly becomes whether the enterprise or a director is on a sanctions list — that is a separate answer, but is often asked in the same round of questions. If you do not have a complete overview of all countries, then "not yet complete, to be supplemented" is a more honest answer than an estimate that is incorrect.

Basis: AML client due diligence, not the Commercial Register

The countries question does not come from the Trade Register Act 2007 — that only records who the enterprise is and where it is established, not who it does business with. The basis is the client due diligence from the Anti-Money Laundering and Combating the Financing of Terrorism Act: the insurer must assess the risks of the relationship, and the country of the counterparty is a standard factor in this. That overview often overlaps with what has already been recorded with the source of the company's assets, because both questions stem from the same risk assessment.

What this is based on

The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.

What you concretely need to do

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This is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.