Insight

Why Reliable Mortality and Goneaway Data is Critical for Compliance in Regulated Markets

Compliance in regulated markets is not optional. In financial services, insurance, utilities, or regulatory technology, organisations must comply with high standards to protect consumers, prevent fraud, and maintain operational integrity. Having access to reliable mortality data and identifying goneaway customers are significant yet often overlooked compliance considerations. Without accurate mortality or goneaway data, firms may risk regulatory breaches, financial penalties, reputational damage, and even litigation.

Published by: MiExact Marketing | 6 March 2025

The Role of Mortality and Goneaway Data in Compliance and KYC Processes

It is necessary for organisations within regulated sectors to have precise mortality data to ensure they are not communicating with deceased customers or misusing customer information. Organisations must also verify that they are not miscommunicating with individuals who have moved and failed to update their contact details; commonly referred to as goneaways. This is important in meeting regulatory standards around accurate communications and avoiding data misuse across a number of major industries:

Financial Services & Banking

The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (UK AML Regulations) require firms to conduct due diligence, including verifying if an individual is deceased before opening accounts or providing financial services. Banks must prevent fraud related to late account holders and make the correct payments under pension arrangements. Incorrect records can lead to overpayments, which will attract regulatory scrutiny and financial loss. Regulatory frameworks such as the Financial Conduct Authority (FCA) Consumer Duty (FCA Consumer Duty) lay down the need for accurate record-keeping and fair customer outcomes. Identity verification is also critical to prevent pension fraud and unauthorised access to deceased individuals' credit profiles. Similarly, goneaway data helps institutions ensure that critical financial communications such as statements, loan documents, and credit decisions are sent to the correct recipient - helping to prevent identity theft, data breaches, and breaches of Consumer Duty.

Insurance

The Insurance Distribution Directive (IDD) (European Insurance Distribution Directive) and the FCA require insurers to verify customer details, including ensuring no fraudulent applications are made in the name of deceased individuals. Non-life and life insurers must validate claims against up-to-date mortality statistics to prevent fraud and settle authentic claims efficiently. The IDD highlights the importance of data accuracy in claims management.

Maintaining up-to-date address data reduces the risk of misdirected claims documentation and ensures customer contact is fair, compliant, and secure - especially where high-value policies are involved.

Utilities & Telecoms

Operators must not distress families by taking unnecessary billing or collection activities on deceased customers. Ofcom (Ofcom Fair Treatment Guidelines) and Ofgem (Ofgem Standards of Conduct) stress the importance of treating customers fairly, including those handling deceased estates. Utilities and telecoms companies must also conduct accurate customer identity checks, including verifying mortality status, to prevent fraud and misallocated accounts.

Goneaway suppression also plays a vital role in operational integrity for these sectors. Bills or debt collection notices sent to outdated addresses can result in misallocated accounts, poor customer experience, and compliance breaches under customer fairness guidelines.

Regulatory Tech & Compliance Businesses

Organisations specialising in compliance need robust mortality data to support anti-fraud measures, identity verification, and regulatory reporting. The UK General Data Protection Regulation (UK GDPR) (UK GDPR Compliance) mandates accurate data processing to prevent misuse and ensure lawful handling of personal data.

Under GDPR, inaccurate or outdated contact records, such as those from goneaway customers, may constitute a data processing breach, especially if sensitive information is sent to an incorrect address.

Potential Consequences of Inaccurate Mortality and Goneaway Data

Inaccurate data can have significant negative consequences, including:

Regulatory Non-Compliance: Failure to comply with regulations such as the aforementioned FCA’s Consumer Duty can result in hefty fines, enforcement actions, and increased regulatory scrutiny. Misdirected communications due to goneaway data are also increasingly seen as regulatory failings under the FCA's fairness and customer outcomes obligations.
Fraud & Financial Crime: Deceased persons' information can be used to facilitate fraudulent activities, e.g., identity theft or benefits fraud. The Proceeds of Crime Act 2002 (POCA) (Proceeds of Crime Act) enforces stringent anti-fraud measures. Similarly, fraudsters frequently exploit goneaway identities to open new credit lines, receive financial correspondence, or redirect services.
Reputational Damage: Incorrectly contacting or attempting to recover money from the relatives of deceased individuals may result in negative publicity and loss of customer trust. The same applies to communications sent to outdated addresses, particularly when sensitive or financial in nature.
Operational Inefficiencies: Handling outdated records incurs administrative expense, creating unnecessary costs and inefficiencies in customer service. Undelivered mail, returned communications, and customer complaints caused by goneaway data contribute significantly to avoidable operational costs.

The Need for Real-Time, Accurate Mortality and Goneaway Screening

Organisations need access to accurate mortality and goneaway data to mitigate these risks. A robust data screening procedure guarantees that businesses are able to:

- Quickly and effectively detect deceased individuals and those no longer residing at recorded addresses.
- Prevent fraudulent activity related to deceased or unreachable client records.
- Comply with industry regulations.
- Improve operational efficiency by automating updates to customer information.

How MiExact Mortality and Goneaway Data Helps

MiExact provides highly accurate and up-to-date mortality data to help organisations within regulated sectors maintain compliance. We also provide goneaway suppression to ensure your customer records are fully up to date. By leveraging comprehensive data sources and advanced verification processes, we help businesses to:

Reduce fraud risks associated with deceased and unreachable identities.
Avoid sending unnecessary and potentially distressing communications to the bereaved or to incorrect addresses
Improve data hygiene and operational efficiency.
Meet regulatory requirements with confidence.

Drive Compliance with Accurate Mortality and Goneaway Data

Rules on data accuracy, anti-fraud controls, and consumer protection are likely to become even more stringent. Organisations have an active duty to ensure their customer records are up-to-date and compliant. That means not only knowing who has passed away, but also who has moved. Investing in accurate mortality and goneaway data also ensures business integrity, consumer trust, and long-term resilience.

To optimise your compliance and KYC processes, request a free MiExact data audit today.