Free Anti-Money Laundering Course

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Insurance Companies Must Establish Anti-Money Laundering Programs

According to a regulation issued by the Financial Crimes Enforcement Network, insurance companies are required to establish anti-money laundering programs in order to protect the insurance industry from criminal abuse and terrorism. This in turn will safeguard the United States financial system as a whole.


Financial products such as insurance have been identified as vulnerable to those looking to money launder and a need has been recognized to pass a more comprehensive anti money laundering scheme by Congress. This is part of the USA PATRIOT Act which was passed in 2001 and extended by President Obama in 2011. The Act focuses on financial institutions such as insurance companies and calls upon the Secretary of the Treasury to administer the final rule on these insurers.

The Final Rule

The final rule doesn’t apply to all insurance companies. According to the definition of insurance company or insurer, any business involved in the issue or underwriting of covered products is susceptible to money laundering.


These terms do not apply to those who provide annuities or covered products incidentally as part of another type of business. These might include charities or organizations which are tax-exempt who may offer annuity products as gifts. In instances such as these, such organizations would not qualify as insurance companies as per the final rule.

Covered Products

Covered products, according to the final rule are defined as:

  • Permanent life insurance, not including group plans
  • Annuities, not including group annuities
  • Insurance products which carry investment or cash value properties.

These definitions are practical in that they encompass the products which have the investment and cash value properties; namely the features which are at greater risk of abuse by money laundering. As a result many types of insurance are omitted under the final rule, such as health insurance, home insurance and term life insurance.


Insurance companies that issue or underwrite insurance products are required to produce written anti-money laundering programs which apply to their covered products as per the final rule. This program must be configured to prevent any of the services that the company provides from being used for money laundering.


A senior manager must approve this program and it must be passed to the Department of the Treasury, should they request it. These programs are risk-based and can be expected to differ according to the size of the company and the amount of compliance resources that the company has in place.


* The information provided is intended for licensed insurance agents only. It is not intended for the purpose of advertising the insurance products to the general public.

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