AML & understanding problems and programs

BSA

Bank Secrecy Act

Not CIP in AML

Criminal background check and fingerprinting

CRT

Currency Transaction Report

CIP

Customer Identification verification procedures Program

Not basic requirements for AML

Development of suitability standards

Currency Transaction Report (CRT)

Form 8300 captures: Identity of the individual from whom the cash was received.

Currency Transaction Report (CRT)

Form 8300 captures:A description of the transaction and method of payment and the name of the business that received the cash

Currency Transaction Report (CRT)

Form 8300 captures:The person on his behalf the transaction was conducted

BSA (Bank Secrecy Act)

Insurance company is encouraged to report Any activity that appears to value the law, regardless of the amount of the transaction.

BSA (Bank Secrecy Act)

Insurance company is required to report suspicious transactions that involve, separately or in the aggregate, at least $5000 in funds or other assets.

BSA (Bank Secrecy Act)

Requirements Exception: failure to verify identifying information through primary sources.

Form 8300 captures

Whether or not Cash was obtained from illegal activities

AML ID checks

Whether the insurance product under consideration is at a low or high risk for money laundering

wire transfer monitored

a financial transaction that electronically moves funds from one bank to another. In AML- to ensure that the insurance company does not accept or send funds to an (OFAC) office of foreign assets control blocked party.