GENERAL ANTI-MONEY LAUNDERING PROGRAM REQUIREMENTS

• Insurance Companies Covered
• Covered Products
• AML Program Elements

REPORTING RESPONSIBILITIES

• Form 8300
• Suspicious Activity Reporting
• Filing SARs for Mutual Fund Accounts

AGENTS/BROKERS

CUSTOMER INFORMATION

COMPLIANCE OFFICER

BSA/AML TRAINING PROGRAM

INDEPDENDENT TESTING FOR COMPLIANCE

SEPARATE REGISTRATION AS BROKER-DEALER

EXAMINATION AUTHORITY

OFAC COMPLIANCE

NATIONAL SECURITY LETTERS

DEFENSE DEPARTMENT AUTHORITY TO OBTAIN INFORMATION

INFORMATION SHARING WITH GOVERNMENT AGENCIES

PROTECTION FROM DISRUPTION

Insurance companies were, prior to 9/11, not generally viewed as target vehicles for money launderers or terrorists, even though regulators had noted that policies would sometimes be purchased and then canceled, or the cash surrender value quickly retrieved, which was sometimes part of the layering process by which a launderer “washed” proceeds of illicit activities and brought it into the mainstream financial system.  In the last few years, the Financial Crimes Enforcement Network has spent considerable effort in analyzing the vulnerabilities of the insurance industry, and the resulting anti-money laundering requirements now justify a checklist designed to help compliance personnel of insurance companies, and their advisors, meet the standards necessary for compliance. 

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