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Section 352(a) of the USA PATRIOT Act requires all covered financial institutions to develop anti-money laundering (AML) compliance programs. On September 26, the Financial Crimes Enforcement Network (FinCEN) of the Department of the Treasury issued a proposed rule to prescribe minimum standards for AML programs for insurance companies. FinCEN's notice identified life insurance products as presenting the most significant money laundering risks in the insurance industry. FinCEN focused the proposed rule on insurance products with investment features as possessing the ability to store value and transfer that value to another person.
The proposed rule requires that each …