Anti-Money Laundering Red Flags

The USA Patriot Act was originally effective April 2002. It was expanded in May 2005 to require any insurance company offering certain products to establish an anti-money laundering (AML) program to help detect and report possible criminal or terrorist activity.

GILICO has trained its employees and producers to be on the alert for suspicious activities, or "red flags," and has set procedures to report any such activity to the Financial Crimes Enforcement Network, FinCEN.

ANTI-MONEY LAUNDERING "RED FLAGS"

RED FLAGS. Some examples of "red flags" associated with existing or potential customers include, but are not limited to, the following:

	1.	The purchase of an insurance product that appears to be inconsistent with a customer's needs;
	2.	Any unusual method of payment, particularly by cash or cash equivalents (when such method is, in fact, unusual);
	3.	The purchase of an insurance product with monetary instruments in structured amounts;
	4.	The early termination of an insurance product, especially at a cost to the customer, or where cash was tendered and/or the refund check is directed to an apparently unrelated third party;
	5.	The transfer of the benefit of an insurance product to an apparently unrelated third party;
	6.	Little or no concern by a customer for the investment performance of an insurance product, but much concern about the early termination features of the product;
	7.	The reluctance by a customer to provide identifying information when purchasing an insurance product, or the providing of minimal or seemingly fictitious information; and
	8.	The borrowing of the maximum amount available soon after purchasing the product.

For additional information, please visit the Financial Crimes Enforcement Network (FinCEN) at www.fincen.gov.

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