USA PATRIOT Act — AML Programs

Requires insurers to maintain a written anti-money-laundering (AML) program with four required elements: (1) risk-based policies, procedures and internal controls; (2) a designated compliance officer; (3) ongoing training of employees and agents; and (4) independent testing of the program, including agent compliance. Cash-value life insurance and annuities are attractive laundering vehicles (dirty money in → clean insurer check out).