Client Agreement

  1. Cipher Risk Limited is authorised & regulated by the Financial Conduct Authority (FCA). Cipher Risk has an FCA number of 956948. You can check this on the Financial Services Register by visiting or by contacting the FCA at 12 Endeavour Square, London E20 1JN or telephone 0800 111 6768 (freephone).
  2. This document is designed to introduce and explain key aspects and important information about the specialist life assurance broking services provided by Cipher Risk. At Cipher Risk, we focus on arranging high value and often complex life assurance cover for corporate clients and high net worth individuals (HNWI). We have unrivalled knowledge of the marketplace and have developed close relationships with the primary insurers, re-assurers, their treaties and the underwriters that make the crucial decisions. Due to the high values of insurance we broker we have access to the best underwriting teams at the leading insurance and reinsurance companies, placing contracts of up to £20 million on individual clients and £100’s of millions of insurance for our corporate clients each year.
  3. This is an important document that should be read carefully and if you are unsure of any of its terms please ask.
  4. The terms of this Agreement come into force immediately on acceptance (implied or actual) of its terms by you and will remain in force until cancelled by us or you or replaced by a later version.

Our Services

  1. For Non-investment protection contracts we are an intermediary and will act on your behalf when providing advice and making our personal recommendation(s) to you. We will do this based on a fair and personal analysis of insurers for term assurance, income protection, critical illness.
  2. Cipher Risk and your adviser are able to advise you on products from the whole of the market.

The Cipher Risk Approach

  1. We have developed a unique process to meet the needs of demanding, time poor and successful clients that is streamlined, open and transparent. Following an introductory meeting where we can identify your needs and/or concerns, discuss likely solutions, present methodology and explain the next steps to obtaining cover.
  2. The first step will be for you to undertake a medical test at a convenient time and place to suit you. We have access to nationwide Doctors and clinics, some of whom can even visit you in the comfort of your own home (dependent upon availability). We will remain your main point of contact throughout and we will keep you fully informed.
  3. The next steps are strictly private and confidential and are as follows:
    • Medical Underwriting – GP and/or specialist records, medical examination reports, internal assessment and medical risk.
    • Financial underwriting – establish financial status, obtain company accounts, internal assessment and financial risk.
    • Brokerage – produce one-page statement of risk before negotiating with insurers and re-insurers to establish provisional terms.
    • Solutions – presentation of internal risk analysis, discuss product options and providers and make recommendations. Advise on Trust and technical structuring of policy.
    • Application – applications made to relevant insurer(s), financial and other supporting evidence provided, trust and agreements put in place, placement of business and on risk status.
    • On risk business – Issuing life assurance contracts.
  4. We are permitted to give advice on Health and Life Protection insurance and arrange transactions in these products.
  5. In order to provide you with personal financial advice and recommendations suitable for your particular circumstances we will undertake a ‘fact find’ to gather the appropriate information to assess your needs. We will then be able to set out clearly your financial planning objectives based on your stated objectives, acceptable level of risk and any restrictions you wish to place on the type of policies you are willing to consider. Details of your stated objectives will be set out in a Suitability Report we will issue to you to confirm our recommendation. Unless confirmed in writing, to the contrary, we will assume that you do not wish to place any restrictions on the advice we give you.
  6. You hereby acknowledge that in the event of the firm assisting you in the completion of any policy proposal forms that you will in any event continue to bear full responsibility for the accuracy and completeness of the information entered on such forms. Therefore, you understand that inclusion of incorrect information or omission of any material facts may result in the policy to which the application or proposal relates to being adversely adjusted, made void and/or any claim(s) made against it being refused. The advice we give you will be based on the information you have given us and your stated objectives including the degree of risk you will accept. It is your responsibility to advise us on any changes.
  7. We will forward to you all documents showing ownership of your contracts as soon as practicable after we receive them. All such documents may be sent by post/email and this would be at your risk.
  8. Unless you inform us whether there are any restrictions as to the type of insurance on which you want advice, we will only provide that service on insurance within our authorisation and that we believe are suitable for you.
  9. We require our clients to give us instructions in writing, or we may confirm our understanding in writing (by post or by email) in order to avoid possible disputes. This will usually be in the form of a proposal or application form. We will, however, accept oral instructions in certain instances provided they are subsequently confirmed in writing.

Customer Classification

  1. The Financial Conduct Authority (FCA) have three levels of client: Retail, Professional and Eligible Counterparties. Different levels of protection apply to each.
  2. We have classified you as a Retail Client and, as such, you will be afforded the highest level of protection.
  3. In the event of an unresolved dispute, you will have a right of referral to the Financial Ombudsman Service (FOS) and may be entitled to benefit from the maximum protection available under the Financial Services Compensation Scheme (FSCS). It should be noted that not all Retail Clients are eligible claimants under the FSCS but, as a private individual, you are classified as an eligible complainant.
  4. This agreement is personal to you and not assignable. We may accept instructions from and give information to third parties or your other advisers on your behalf where you have confirmed in writing we may do so. We cannot accept any responsibility for errors in information supplied by such persons. Where you are a trustee, director or officer of any trust, corporation or LLP requiring advice you warrant to us that you have full authority to act on behalf of the same and there are no restrictions on the limits of our advice of which we have not been made aware. We will not be responsible for advising on compliance with your trust, trustee, director or officer obligations.

The Cost of Our Services

Protection Insurance

  1. For Protection Insurance we do not charge a fee. We will receive commission from the insurance provider on a non-indemnity or indemnity basis.
  2. We do not normally charge you a fee for arrangement of an insurance product as we will receive a commission from the product provider. If, however you cease to pay premiums and the policy is subsequently cancelled the provider will claw back a proportion of the commission that has been paid to us. As this commission covers the cost of our service to you, we will charge you a fee equal to the amount of commission that we have to refund to the provider.
  3. Before a policy is put into force, we will write to you to inform you of the commission we will receive. This will be the maximum amount we will charge you, together with the maximum period of claw back. This will usually be for a period of between 2 to 4 years.
  4. The amount of commission we receive will vary depending on the type of policy and (sometimes) the term of the policy or your age.

Client Money

  1. For your additional security we do not handle client’s money. We never accept a cheque made out to us (unless it is a cheque in settlement of our fees or other charges or disbursements for which we have sent you an invoice). We do not handle cash. Cheques for payment will be required to be paid direct to the insurance provider.

Accounting to You

  1. We will make arrangements for all your contracts to be registered in your name unless you first instruct us otherwise in writing. You have a right to inspect copies of contract notes and entries in our records in relation to transactions on your behalf. In that request we reserve the right to give you copies of such documents rather than access to the original records.
  2. We will forward to you all documents showing ownership of your policies as soon as practicable after we receive them. Where a number of documents relating to a series of transactions is involved, we will normally hold each document until the series is complete and then forward them to you.

Financial Services Compensation Scheme (FSCS)

  1. If you make a complaint and we are unable to meet our liabilities, you may be entitled to compensation from the Financial Services Compensation Scheme.
  2. Further information about the limits applicable to the different product types is available from the FSCS at


  1. If you should have any complaint about the advice, you receive or a product you have bought, please write or call Cipher Risk – 40 Gracechurch Street, London, EC3V 0BT,, 020 3440 3665.
  2. If following our subsequent investigation and response you are still not satisfied you may contact the Financial Ombudsman Service (; South Quay Plaza, 183 Marsh Wall, London, E14 9SR). Full details are contained within our internal complaint’s procedure, which is available to you on request at any time.

Cancellation Rights

  1. The cancellation rights for each individual policy you have been advised on will be explained to you in your suitability report which we will give you before or at the time you confirm or carry out the transaction. Where the provider is already in receipt of the premium and cancellation is requested within the cancellation period, we will instruct the provider to refund the proceeds net/gross of the adviser charging agreed.

Material Interests/Conflict of Interests

  1. Occasions can arise where we, or one of our other customers, will have some form of interest in business, which we are transacting for you.
  2. As a consequence of such potential conflicts arising, we have put arrangements in place to ensure all our clients are treated fairly.
  3. We have also implemented a conflicts of interest policy to help us to all appropriate steps to manage such risks.
  4. While we take all appropriate steps to mitigate such risks, if we are unable to mitigate the risks from a potential conflict, before we undertake any actions on your behalf, we will inform you in writing with:
    • A specific description of the conflicts that has arisen.
    • A clearly documented statement of the steps the firm has taken to prevent the conflict.
    • An explanation of the remaining risks that are posed to your interest.

Risk Warnings

  1. Relevant risk warnings will be advised to you throughout the financial planning process and in your suitability report.
  2. For insurance products, your insurance policy may lapse if you do not keep up to date with regular premium payments and you may not be covered if a claim is made.

Termination of Authority

  1. You or we may terminate our authority and/or this agreement to act on your behalf at any time without penalty. Notice of this termination must be given in writing and will take effect from the date of receipt. Termination is without prejudice to any transactions already initiated which will be completed according to this client agreement unless otherwise agreed in writing. You will be liable to pay for any transactions made prior to termination and any fees which may be outstanding.

Anti-Money Laundering

  1. We are required to verify your identity in accordance with the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2007. We reserve the right to approach third parties and to delay any applications until adequate verification of identity has been obtained.

Governing Law & Jurisdiction


  1. We reserve the right to amend this agreement at our discretion where changes in regulation or law necessitate by giving you notice in writing. You will also be given the option to accept our new agreements or terminate our authority. This agreement shall be governed by and construed according to English law. Any disputes shall be determined in the jurisdiction of the English Courts.
  2. Where a formal written notice is required by this agreement then it shall be in writing (not email unless agreed in advance by the parties) and sent by first class post and deemed effective two business days after posting.