Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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6/12/2006 Insurance Companies Should Use SAR-SF Until SAR-IC Is Released

FinCEN has indicated that until a proposed Suspicious Activity Report for Insurance Companies (SAR-IC) is released, insurance companies should use the SAR for the securities and futures industries (FinCEN Form 101, SAR-SF). Insurance companies have been required to file SARs since May 2, 2006. In preparing the form, on page 2, part iv, #36, after entering the name of the insurance company, there should be a space followed by “SAR-IC.” In the narrative to the SAR, the first line should read “Insurance SAR.” The guidance acknowledges that not all insurance companies had trained all agents and brokers regarding AML issues by May 2, 2006, but by that date all should have formally adopted written AML policies and procedures that include reasonable plans for training all appropriate agents and brokers. A revised chapter on insurance company issues will be appended to the July issue of the Monitor and will be part of the next supplement to the treatise.

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