Although insurance agents are not required by FinCEN to file Suspicious Activity Reports (SARs), they are expected to gather all necessary customer information, make observations and report suspicious activity to the insurer’s AML compliance officer. A single observation of suspicious activity does not automatically mean that money laundering has occurred. Nevertheless, insurance agents are to error on the side of caution and report any and all potentially suspicious activities to the insurer. The insurer will then consider all the evidence and determine if a SAR should be filed.
The topics presented in this lesson are: