Insurance covered-product AML
Working draft · Version 1 · Research date 2026-09-14
1. Purpose and scope
Federal insurance AML program duties attach to issuers or underwriters of defined covered products. The rule excludes agents and brokers from its insurer definition, although an insurer must integrate its distribution network into its program. Product and role facts matter.
Covered products include non-group permanent life insurance, non-group annuities and other products with cash-value or investment features. An agent or broker alone is not an insurer under this rule.
2. Adoption and accountability
The accountable policy owner must confirm the legal entity, products, customer locations, applicable laws and exemptions before adoption. Maintain an applicability register and obtain management approval of procedures, owners, retention and deadlines. This template does not claim legal review or complete compliance coverage. An industry selection is a suggestion, not evidence of a legal duty.
3. Operating controls
3.1 Approve a covered-product AML program
Owner: AML compliance officer. Trigger: Before covered-product activity and after material risk changes.
Document product and distribution risks, controls and senior-management approval. Designate the compliance officer responsible for implementation and updates. Distinguish uncovered lines and any other independently applicable AML rules.
Evidence: Approved AML program and covered-product inventory.
3.2 Integrate distribution and risk monitoring
Owner: AML operations lead. Trigger: During covered-product distribution and servicing.
Obtain relevant customer information through agents and brokers, monitor defined risk indicators and investigate unusual activity. Record control gaps, escalation and accountable follow-up.
Evidence: Distributor control record and investigation log.
3.3 Train and independently test the program
Owner: AML compliance officer. Trigger: At onboarding and at risk-based training and testing intervals.
Train appropriate staff and distribution personnel, or verify qualifying third-party training. Arrange independent testing by a qualified person outside the compliance-officer role and track remediation.
Evidence: Training evidence and independent test report.
3.4 Control suspicious-activity decisions and records
Owner: AML compliance officer. Trigger: When facts raise a possible covered-product suspicious-activity report.
Escalate to the authorized AML reviewer to apply reporting criteria and deadlines. Preserve supporting records and restrict SAR information to permitted recipients; do not disclose SAR existence to the subject or place SAR content in this public application.
Evidence: Restricted case record, filing decision and retention controls.
4. Exceptions, review and records
Log deviations with the affected control, risk, interim action, owner and resolution date. Escalate missed statutory duties immediately to the responsible compliance lead; internal exceptions cannot waive law. Keep versioned approvals and follow the confirmed retention schedule and any legal hold. Review after material legal, product or operating changes.
5. Authorities and limitations
- FinCEN insurance company rules: 31 CFR §§1025.100, 1025.210 and 1025.320.
- Research as of 2026-09-14; confirm the current operative requirements.
- Template status: draft, awaiting organization-specific and legal review.
- Company review cadences, operational steps and evidence examples are proposed implementation controls, not quotations from law.