Our insurance agency at the holding compnay level acquired 100% of another insurance agency.

Please forgive me if asking a DUMB question BUT bear with me - what specific BSA/AML issues, if any do I need to address? Is the bank's role that of a 3rd party-agent selling covered insurance products? Per the exam manual, the insurance regulations apply only to the insurance companies; there are no independent obligations for brokers and agents. It further states the insurance company is responsible for the conduct and effectiveness of its AML compliance program which includes agent and broker activities.