Producer s Guide to Anti-Money Laundering

Transcription

1 As an insurance prducer, yur skills and services help yur clients achieve financial success and security. Because yu are n the frnt lines f a multi-billin dllar industry, yu are in a unique psitin t nt nly serve yur clients, but als serve yur cuntry by helping t prevent mney laundering and the financing f terrrist activities. The Treasury Department s Financial Crimes Enfrcement Netwrk (FinCEN) has issued regulatins requiring insurance cmpanies t establish anti-mney laundering ( AML ) prgrams that include, amng ther things, the integratin f agents and the reprting f suspicius transactins. Agent integratin cnsists f many cmpnents including but nt limited t the requirements set frth in this Guide. Phenix must take steps t ensure that all transactins cmply with these AML regulatins. As a Phenix prducer yu have an imprtant rle t play in ur AML prgram. T that end, yu must cmply with the fllwing requirements when selling Phenix s individual life insurance and annuity prducts: 1. RECEIVE ANTI-MONEY LAUNDERING TRAINING EVERY TWO YEARS: Every tw years yu must review and understand yur bligatins with respect t Phenix s AML Prgram as utlined in this Guide, including becming familiar with Phenix s Cvered Prducts and the ptential risk fr mney laundering with these prducts. - AND - Every tw years yu must receive cre AML training thrugh ne f the fllwing measures: Take the LIMRA AML nline training curse at [Please refer t Attachment A fr directins n hw t lgin and use the LIMRA nline training curse] - OR - Check with yur Brker Dealer/Agency t determine if ther Phenix apprval has been btained. 2. KNOW YOUR CUSTOMER: Yu must ensure that all custmer infrmatin n the prduct applicatin and assciated dcumentatin is cmplete and accurate. In ther wrds, yu must prvide custmer infrmatin t us abut yur clients and their financial activities. The fllwing infrmatin shall be required in all instances befre an applicatin may be established fr a custmer: Individual Name Telephne number Address (P.O. Bx nt acceptable) Scial Security Number Date f Birth Occupatin Business Name Telephne number Mailing address f business r principal place f business Tax identificatin number Type f Business Organizatin Ownership Infrmatin abut the Business The infrmatin abve is the minimum infrmatin required by Phenix in rder t prcess an applicatin. Yu shuld als prvide any additinal custmer infrmatin that is required by yur individual Brker Dealer/Agency. HO5137 Page 1 f

2 Enhanced Due Diligence - There are certain types f custmers wh may pse a higher risk f engaging in mney laundering activities, and fr whm additinal due diligence is required. These types f custmers include but are nt limited t: Nn-resident aliens r freign custmers, Custmers wh resist prviding identifying infrmatin, Senir freign plitical figures and their immediate family members, and Nn-gvernmental suspicius rganizatins r charities. 3. ACCEPT ONLY THE FOLLOWING TYPES OF PAYMENT FROM CUSTOMERS: Checks written frm an individual r crprate accunt payable t Phenix, Checks written frm an individual r crprate accunt, payable t a trust and endrsed ver t Phenix, Freign checks payable t Phenix. The check must be paid thrugh a U.S. Bank (Crrespndent Bank) as nted n the frnt f the check and must be in U.S. currency, Mney Orders, Bank Checks, r Starter checks may r may nt be accepted depending n Phenix s verificatin f the custmer s name and address that is cnsistent with the infrmatin prvided n the applicatin. [Please refer t Attachment B fr a cmplete list f acceptable frms f payment] 4. NOTIFY PHOENIX IF YOU DETECT ANY MONEY LAUNDERING RED FLAGS, SUCH AS: The purchase f a prduct that appears t be incnsistent with a custmer s needs r exhibits lack f cncern regarding investment risk, Little r n cncern by a custmer fr the investment perfrmance f an insurance prduct, but much cncern abut the early terminatin features f the prduct, Custmer reluctance t prvide identifying infrmatin, r the prvisin f infrmatin that seems fictitius (Fr example, a New Yrk phne number with a Texas address), Custmer is unusually curius abut cmpliance prcedures, Plicy wner and/r insured fcus n the administrative aspects f prcedure (such as cmpliance, etc) versus the purchase itself, Plicy wner and/r insured purchases multiple plicies where insured differs n each f the plicies, Plicy wner and/r insured has a recent substantial change in financial histry, r Any ther activity that yu reasnably believe may be suspicius. [Please refer t Attachment C fr a cmplete list f red flags] IF YOU DETECT RED FLAGS OR SUSPICIOUS ACTIVITY, YOU MUST CONTACT PHOENIX S CORPORATE COMPLIANCE DEPARTMENT ON THE AML HOTLINE AT OR VIA AT amlcmpliance@nsre.cm. PLEASE NOTE THAT A REFERRAL TO THE COMPLIANCE DEPARTMENT IS TREATED CONFIDENTIALLY AND MAY NOT BE DISCUSSED WITH ANY THIRD PARTIES. YOU MUST NOT, UNDER ANY CIRCUMSTANCES, DISCLOSE THE FACT THAT A SAR HAS BEEN FILED, OR EVEN CONSIDERED, TO THE SUBJECT OF THE SAR OR TO ANY THIRD PARTIES. HO5137 Page 2 f

3 Attachment A LIMRA ANTI-MONEY LAUNDERING ( AML ) PRODUCER TRAINING FREQUENTLY ASKED QUESTIONS Q: Hw d I access the CFM Netwrk training site? A: Open Internet Explrer and g t Lgging In Q: Hw d I lgin t the CFM Netwrk? A: T lgin t the CFM Netwrk, yu must be a registered user. In rder t be a registered user Phenix needs t prvide yur name t LIMRA. Initial Lg in Instructins: When yu lg int the LIMRA website yu will see the fllwing: HO5137 Page 3 f

4 If yu are already registered, please fllw the steps listed belw. On the Lgin Page ( enter yur username and passwrd in the spaces prvided. Please nte that the lgin functin is case-sensitive. Click n the Lgin buttn. Username: First 4 Characters f yur last name and the last 6 digits f yur scial security number (must be lwercase!). Passwrd: If this is yur first time lgging in, the passwrd is yur last name (lwercase). After yu lg in fr the first time, yu will be immediately asked t change yur passwrd. Fr example: Prducer s name is Jhn Smith and scial security number is His lg in infrmatin wuld be as fllws: Username: smit Passwrd: smith If yu have lgged in previusly, yu shuld use the passwrd yu created the first time yu lgged in. If yu have frgtten yur passwrd, click the Frgt Yur Passwrd link and fllw the prmpts t reset it. Errr Messages Q: I fllwed the steps t lgin t the CFM Netwrk, but I received a message that says Yu have entered an invalid Username. Please try again. What des this mean? A: This message indicates that the username infrmatin entered des nt match ur list f active accunts. If yu are registered and receive this message, it culd be fr several reasns: Yur username was typed incrrectly. Make sure yur Caps Lck is ff, that yu are typing each character in lwercase, and that yu are nt transpsing any f the characters. If yu believe the infrmatin yu entered is crrect and yu cntinue t receive this message, please cntact ur supprt staff at supprt@cfmpartners.cm r (866) Q: I fllwed the steps t lgin t the CFM Netwrk, but I received a message that says Yu have entered an invalid Passwrd. Please try again. What des this mean? A: This message indicates that the passwrd entered des nt match the username. If yu receive this message, it culd be fr several reasns: Yur passwrd was typed incrrectly. Make sure yur Caps Lck is ff, that yu are typing each character in lwercase, and that yu are nt transpsing any f the characters. Yu have lgged int the site befre, but are entering yur last name as yur passwrd. Instead, yu shuld use the passwrd yu created the first time yu lgged in. If yu have frgtten yur passwrd, click the Frgt Yur Passwrd link and fllw the prmpts t reset it. Yu have never lgged int the site befre, but are entering a passwrd ther than yur last name. Instead, try entering yur last name. If yu believe the infrmatin yu entered is crrect and yu cntinue t receive this message, please cntact ur supprt staff at supprt@cfmpartners.cm r (866) Q: I have lgged int the CFM Netwrk previusly but have frgtten my passwrd. Hw d I reslve this situatin? A: Click n the Frgt Yur Passwrd link fr instructins. If yu need further assistance, cntact ur supprt staff at supprt@cfmpartners.cm r (866) HO5137 Page 4 f

5 Taking the Curse Q: Hw d I begin a curse? A: Once yu are lgged in, yu will be brught t the Hme Page. The Hme Page lists the curse(s) yu are enrlled in, prvides a brief descriptin f the curse(s), and indicates yur prgress. T begin the curse, click n the curse title. The Table f Cntents is the first screen that yu will see upn entering the curse. It lists the sectins f the curse and the percentage cmpleted fr each lessn. T start the curse, click n the title f the first sectin. Yu may als return t a cmpleted lessn r t ne in prgress by clicking its link. Q: Des my perfrmance n Learning Checkpints and Case Studies cunt tward my grade fr the curse? A: N, scres fr Learning Checkpints and Case Studies are nt recrded. Learning Checkpints and Case Studies allw yu t test yur understanding f the infrmatin presented. Yu are permitted tw attempts t select the crrect answer. If, n the secnd attempt, yu have nt identified the crrect answer, it will be prvided t yu. Yu may als g back thrugh the curse and review the curse infrmatin. HO5137 Page 5 f

6 Attachment B ACCEPTABLE FORMS OF PREMIUM PAYMENT The fllwing frms f payment can be accepted Checks written frm an individual r crprate accunt payable t Phenix, Checks written frm an individual r crprate accunt, payable t a trust and endrsed ver t Phenix, Freign checks payable t Phenix. The check must be paid thrugh a U.S. Bank (Crrespndent Bank) as nted n the frnt f the check and must be in U.S. currency, Mney Orders, Bank Checks, Starter checks may r may nt be accepted depending n Phenix's verificatin f the custmer's name and address that is cnsistent with the infrmatin prvided n the applicatin. The fllwing checks may r may nt be accepted Checks received frm a crpratin r custdian bank payable t an individual, endrsed t Phenix Fr 1035 exchanges, qualified rllvers, etc., the check may be accepted. All thers are generally nt accepted, requests fr acceptance must have Cmpliance apprval, Unendrsed checks will nt be accepted under any circumstances. Checks received frm a crpratin r custdian bank payable t a brkerage firm with a selling agreement with Phenix If it is determined that the brkerage firm has a selling agreement with Phenix, and the check is endrsed ver t Phenix, the check will be accepted. Starter Checks These are checks either with lw numbers (i.e. 101) r n numbers at all, withut names and addresses imprinted n them, Call must be made t the bank t verify individual and address matches ur data, Verified checks will be accepted, Unverified checks will nt be accepted. Prducers shuld be aware that due t privacy restrictins many banks will nt verify custmer accunt infrmatin, and if nt verified Phenix will be unable t accept the starter check. HO5137 Page 6 f

7 The fllwing checks will NOT be accepted Checks received frm a crprate checking accunt payable t anther crpratin and frwarded t Phenix fr depsit int anther crprate accunt, Checks written frm an individual accunt, payable t anther individual r cmpany and endrsed ver t Phenix, Freign checks (in US currency payable t an individual r entity and endrsed ver t Phenix), Travelers Checks, Mney Orders drawn n freign entities, Checks with the date missing r incmplete, Stale dated checks r checks dated mre than 10 days in the future, Checks with n r the wrng payee. HO5137 Page 7 f

8 Attachment C Prducer s Guide t Red Flags Red Flag Definitin A red flag is a sign f an unusual r suspicius activity that may indicate mney laundering r ther illegal behavir is taking place. A red flag, hwever, is nt, in f itself a cnfirmatin that illegal activity is actually taking place. Sme red flags may be the result f perfectly lgical and inncent causes. Yur Obligatin As a prducer f Phenix Life Insurance Cmpany ( PLIC ), yu have an imprtant rle t play in ur AML Prgram and are in the unique psitin f helping t prevent mney laundering by assisting in the identificatin f ptential suspicius activity by mnitring fr and reprting f red flags. If yu determine that smething may be suspicius yu must investigate the nature f the red flag and immediately cntact the Crprate Cmpliance Department n the AML Htline at r via at amlcmpliance@nsre.cm. Pint f Sale Red Flags While it is nt pssible t define every situatin where activity is suspicius, yu are respnsible fr mnitring and reprting the fllwing red flags: 1. Infrmatin Red Flags; Plicy Owner and/r Insured is reluctant t prvide identifying infrmatin including the type f business they are invlved in and/r their verall assets, Plicy Owner and/r Insured prvides false infrmatin, Plicy Owner and/r Insured prvides infrmatin that is incnsistent r suspicius, Plicy Owner and/r Insured prvides unusual business dcuments, Plicy Owner and/r Insured appears t be acting as an agent fr an undisclsed principal, but is evasive abut prviding, r declines r is reluctant, withut legitimate cmmercial reasns, t prvide infrmatin regarding the undisclsed principal, Plicy Owner and/r Insured has difficulty describing the nature f his r her business r lacks general knwledge f his r her industry; in the case f a business accunt, Fr n apparent reasn, the Plicy Owner and/r Insured has multiple accunts under a single name r multiple names. 2. Methd f Payment; Plicy Owner and/r Insured insists n dealing nly in cash r cash equivalents, r asks fr exemptins frm PLIC s cash and/r cash equivalent plicies, The address n the Plicy Owner s and/r Insured s check is different frm the applicatin, HO5137 Page 8 f

9 Plicy Owner and/r Insured inquiries abut alternate payment methds, Plicy Owner and/r Insured pays with 3 rd party check, Wire transfers payment frm jurisdictin nt lgical fr the plicy wner and/r insured (i.e. tax haven), Plicy Owner and/r Insured prvides false, misleading r substantially incrrect infrmatin cncerning surce f funds, Plicy Owner and/r Insured refuses t identify r fails t indicate a legitimate surce f funds. 3. Plicy Owner and/r Insured is verly cncerned with cmpliance prcedures; Plicy Owner and/r Insured is cncerned abut Identificatin plicies, Plicy Owner and/r Insured fcuses n the administrative aspects f prcedures versus the purchase itself, Plicy Owner and/r Insured inquires abut cmpliance prcedures in general. 4. Plicy Owner and/r Insured is willing t nly meet at a lcatin that is unusual. 5. Plicy Owner and/r Insured exhibits a lack f cncern regarding investment risks; cmmissins; surrender charges; sales charges; r ther transactin csts. 6. Plicy Owner and/r Insured is cncerned and asks questins as t hw sn they can withdraw mney ut f their accunt (i.e. free lk; brrw maximum; early surrender). 7. Plicy Owner and/r Insured engages in transactins that lack business sense r appear incnsistent with stated investment strategy. 8. Plicy Owner and/r Insured is attempting t purchase plicy that appears t be abve their needs. 9. Plicy Owner and/r Insured purchases multiple plicies where insured differs n each f the plicies. 10. Plicy Owner and/r Insured has a recent substantial change in financial histry. 11. Plicy Owner and/r Insured is an alien residing in the U.S. in an Office f Freign Asset Cntrl ( OFAC ) sanctined r Financial Actin Task Frce ( FATF ) nn-cperative jurisdictin. 12. Plicy Owner and/r Insured is a U.S. Citizen living abrad in an OFAC sanctined r FATF nn-cperative jurisdictin. 13. Plicy Owner and/r Insured is a nnresident alien r freign custmer. 14. Any ther suspicius activity. HO5137 Page 9 f