We have an insurance division whereas we sell insurance as an agent - it is a subsidiary of the holding company.

I know that the true Insurance Agency is responsible for having an AML program and as part of that, performing CIP on it's clients / customers.

If your bank has the same type of insurance set-up, do you include and have an internal CIP program for your "agents" / insurance division to follow, even though not required? After all, the Bank would not want to do business with anyone that has not been identified with ID verification and the four tenants being obtained?