Regulatory Alerts2006-12-12
Added
Frequently Asked Question Customer Identification Programs and Banks Serving as Insurance Agents
A person purchasing insurance through a bank acting as an agent for an unaffiliated insurance company has not established an account for purposes of the Customer Identification Program rule under 31 C.F.R. § 103.121. This determination applies because the bank’s role is limited to effecting the sales transaction without executing account agreements or maintaining a formal banking relationship with the purchaser. Although the Customer Identification Program requirements do not apply in this scenario, the bank must conduct risk-based due diligence consistent with its anti-money laundering program.