Alerts

Final Anti-Money Laundering Program and Suspicious Activity Reporting Rules for Insurance Companies

November 21, 2005
SRZ Client Memorandum

On October 31, 2005, the Financial Crimes Enforcement Network (“FinCEN”) issued two final anti-money laundering rules affecting insurance companies.  The first rule requires certain insurance companies to establish anti-money laundering ("AML") programs as required under section 352 of the USA PATRIOT Act.  The second rule requires those same insurance companies to file suspicious activity reports ("SARs") with FinCEN pursuant to section 356 of the USA PATRIOT Act. At the same time, Treasury provided an FAQ to assist insurance companies in understanding the scope of the final rules, and invited comments to a proposed information collection form for SAR reporting entitled the "SAR-IC."