Regulatory Alerts2006-05-31
Added
Frequently Asked Questions Anti-Money Laundering Program and Suspicious Activity Reporting Requirements for Insurance Companies
The guidance clarifies that group life insurance policies and group annuities are excluded from the definition of covered products under 31 C.F.R. § 103.137, while confirming that insurance companies are not currently subject to a mandatory Customer Identification Program rule. It mandates that insurance companies begin reporting suspicious activity on May 2, 2006, using FinCEN Form 101 (SAR-SF) with specific notation until the new FinCEN Form 108 becomes available. Additionally, the document acknowledges that some insurers may require additional time to train agents and brokers by the May 2, 2006 applicability date, provided they have formally adopted written anti-money laundering policies and procedures by that deadline.