As part of my insurance company's conditions for pilots all are required to have a checkout by a CFI (does not have to be a CFI from the country of registration - he is not giving instruction in this instance).
Without knowing what the insurance company believes constitutes a "check-out" for the purpose of flying the acrft all answers are speculation.
To me being "checked out" prior to flying an acrft for hire as example this could easily be done by any current pilot (not instructor)who knows the acrft and is happy with the conduct of the flight by the new pilot. WHY does every flight have to have an instructor (A CFI!!!) IF an instructor is required, are lowly FI's incapable of flying a "check flight"??? Utterly ridiculous.