One of the most common methods of money laundering in the insurance industry is to purchase a policy with illicit funds and then request a refund of the premiums, either partially or fully, before the policy matures. This way, the money launderer can receive a legitimate payment from the insurance company, effectively washing the dirty money. This technique is also known as premium fraud or early surrender12 According to the Financial Crimes Enforcement Network (FinCEN), the most significant money laundering and terrorist financing risks in the insurance industry are found in life insurance and annuity products, because such products allow a customer to place large amounts of funds into the financial system and seamlessly transfer such funds to disguise their true origin34 Some indicators of potential money laundering through insurance products are: 12
* The customer pays the premiums with cash, cashier's checks, money orders, or other anonymous or unusual payment methods.
* The customer overpays the premiums or makes multiple payments in excess of the required amount.
* The customer cancels the policy during the free-look or grace period and requests a refund to a different account or a third party.
* The customer purchases a policy that is inconsistent with their income, age, or risk profile.
* The customer shows little interest in the benefits or terms of the policy, but is more concerned about the cancellation or surrender options.
References:
* 1: AML in Insurance: How to Detect & Combat Money Laundering, ComplyAdvantage, 2022
* 2: Anti Money Laundering (AML) In Insurance Industry In 2021, Financial Crime Academy, 2023
* 3: Money laundering in the insurance industry, Insurance Commission, 2022
* 4: Money laundering in the insurance industry, Atty. Dennis B. Funa, Business Mirror, 2016
* [5]: Anti-Money Laundering Requirements: FAQs for Insurance Companies, FinCEN, 2005

According to the Wolfsberg Group's Statement on the Suppression of the Financing of Terrorism1, a compliance officer should include the following three procedures in revising an institution's CTF efforts:
* Consulting applicable lists and taking appropriate actions to determine if customers appear on such lists.
This procedure is important to prevent terrorist organizations from accessing the financial services of the institution and to comply with the sanctions and regulations imposed by competent authorities. The compliance officer should implement procedures for checking the customers against the lists of known or suspected terrorists or terrorist organizations issued by relevant authorities and taking reasonable and practicable steps to verify the identity and status of the customers.
* Reporting matches from lists of known or suspected terrorists to relevant authorities. This procedure is important to assist the authorities in their efforts to detect and disrupt terrorist financing and to fulfill the legal obligations of the institution. The compliance officer should report to the relevant authorities any matches from the lists of known or suspected terrorists or terrorist organizations consistent with the applicable laws and regulations regarding the disclosure of customer information.
* Maintaining customer information to facilitate timely retrieval of such information. This procedure is important to enable the institution to respond promptly and effectively to the enquiries and requests from the authorities and to enhance the quality and accuracy of the customer data. The compliance officer should explore ways of improving the maintenance of customer information to facilitate the timely retrieval of such information.
References:
* Wolfsberg Statement on Anti-Terrorism Financing
UNUSUAL CUSTOMER IDENTIFICATION CIRCUMSTANCES
* Customer furnishes unusual or suspicious identification documents or declines to produce originals for verification."

the compliance officer should cooperate with the law enforcement investigation, but only after receiving a formal written request that specifies the scope and purpose of the information sought. This is to ensure that the compliance officer complies with the legal and regulatory obligations of the bank, such as confidentiality, privacy, and data protection. The compliance officer should also document the request and the information provided, and report the incident to the senior management and the board of directors as appropriate.
References:
* FFIEC BSA/AML Assessing the BSA/AML Compliance Program - BSA Compliance Officer, section
"BSA Compliance Officer", paragraph 3: "The BSA compliance officer is responsible for ensuring that the bank's BSA/AML compliance program is implemented effectively, including timely updates in response to changes in regulations or business activities, and for managing all aspects of the BSA/AML compliance program. The BSA compliance officer is also responsible for ensuring that the bank's BSA/AML compliance program is communicated to all personnel and that adequate training is provided to appropriate personnel."
* Guidelines on the role of AML/CFT compliance officers, section "Guidelines on the role of AML/CFT compliance officers", paragraph 36: "The AML/CFT compliance officer should ensure that the institution cooperates with the competent authorities, including by providing them with all the information they require in a timely manner, in accordance with the applicable legal and regulatory framework."
* Anti-Money Laundering Compliance Officer Job Description, section "Responsibilities of an AML Compliance Officer", bullet point 6: "Cooperate with law enforcement and regulatory bodies as required."

The primary international authoritative body that designates sanctions is the United Nations (UN). The UN Security Council has the power to impose sanctions under Chapter VII of the UN Charter, which deals with threats to the peace, breaches of the peace, and acts of aggression. The UN sanctions are legally binding on all UN member states and aim to maintain or restore international peace and security. The UN sanctions can target individuals, entities, groups, sectors, or countries, and can include measures such as arms embargoes, travel bans, asset freezes, trade restrictions, or diplomatic isolation. The UN sanctions are implemented and enforced by the member states, with the assistance of the UN Secretariat and other specialized agencies. The UN sanctions are periodically reviewed and adjusted by the Security Council, based on the reports of the sanctions committees and expert panels.
References:
* 1: UN Sanctions1
* 2: UN Charter, Chapter VII2
* 3: ACAMS Study Guide for the CAMS Certification Examination3

Wire transfer requests initiated by phone and internet should be included in the review of the customer's activity, as they may indicate a higher risk of fraud, identity theft, or money laundering. Phone and internet wire transfers are more vulnerable to cyberattacks, phishing, or social engineering, and may bypass some of the verification and authentication procedures that are applied to in-person or paper-based requests. Therefore, the compliance officer should monitor these requests for any signs of unusual or suspicious activity, such as changes in beneficiary, amount, frequency, or destination of the wires.
References:
* ACAMS CAMS Certification Study Guide, 6th Edition, page 41
* ACAMS CAMS Certification Exam Outline, 6th Edition, Domain 2, Task 2.1
* ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.1
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 325