Find The AML Surveillance Software for Insurance Companies
Insurance companies that issue or underwrite covered products that may pose a higher risk of money laundering must comply with Bank Secrecy Act/anti-money laundering (BSA/AML) program requirements. A covered product includes:
An
annuity contract other than a group annuity contract
A
permanent life insurance policy other than a group life insurance policy
Any
other insurance product with cash value or investment features
Insurance
regulations only apply to insurance companies, excluding agents and brokers
from the requirements. However, insurance companies are held responsible for
compliance with their program, which includes the activities of any agents and
brokers. Insurance companies should therefore integrate their agents and
brokers into their AML program.
Features
of a BSA/AML program
Insurance
companies must develop a written, risk-based BSA/AML program addressing the
covered insurance products. At a minimum, the program must consist of the
following features:
A
designated compliance officer responsible for effectively implementing the
program
Ongoing
training of appropriate persons, including insurance agents and brokers
Policies,
procedures and internal controls tailored to the AML risks of the institution
Independent
testing to monitor ongoing compliance, including testing for compliance of
insurance agents and brokers
Along
with implementing an adequate BSA/AML program, insurance companies are subject
to suspicious activity reporting (SAR) requirements. Companies are required to
submit a SAR to the Department of Treasury’s Financial Crimes Enforcement
Network. Insurance companies must obtain relevant customer information from
agents, brokers and any other sources to report such transactions.
Areas
of concern to review
Insurance
companies face the challenge of developing an AML
surveillance software program that incorporates insurance agents and
brokers, and effectively covers the risks proportionate to its specific
products offered. Any areas of concern can be addressed by conducting the
following reviews:
Policies
and procedures: Evaluate policies and procedures to determine adequacy given
the institutions’ risks and current industry regulatory requirements
AML
risk assessments: Assess the inherent and residual AML risks related to
products, services, customers and geographic exposure
Model
validations and AML surveillance automated system data
validation: Determine if the appropriate AML models and systems are effectively
implemented
Independent
audits: Conduct independent reviews and detailed AML transactional testing
to ensure the program’s ongoing compliance
Training: Review
staff training programs to ensure adequate coverage of relevant responsibilities
under the program
Risk-based
review: Determine and assess the total effectiveness of AML-related
processes and internal controls in relation to the specific products, services,
customers and geographies of the company, including staffing levels and
expertise, customer due diligence processes, effectiveness of the monitoring
processes in place to identify and report suspicious activities, and the
integration of insurance agents and brokers into the program
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