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#22379 - 06/28/02 09:22 PM OFAC & KYC - Ins. Premium Finance

Does anyone out there have an insurance premium finance department WITHIN their bank? Im trying to write procedures. How are you dealing with OFAC and KYC? Our department is not currently receiving anything from the agent that would indicate who the principals are of a company let alone if the company is registered. And there is no documentation of ID.


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General Discussion
#22380 - 06/29/02 12:28 AM Re: OFAC & KYC - Ins. Premium Finance
Bear Collector, CRCM Offline
Diamond Poster
Bear Collector, CRCM
Joined: Nov 2000
Posts: 1,830
District of Columbia
We do not have an insurance premium finance department within our bank, but I am running into the same KYC (EDD) issues with our affiliated insurance agency. However, if they didn't collect ID before, they are about to start! (like it or not!) I have been asking around about KYC training for insurance companies and agencies, and trying to find out what indicators of suspicious activity an insurance company might encounter. I have spoken to the ABIA, and have a person calling me back from another company in a few weeks. (I am leaving on vaction tomorrow). All I know right now is that it is very hard to convince our insurance agency that all this "BSA stuff" applies to them. I'll post here if I find anything more on this topic.
Being kind is more important than being important.

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#22381 - 07/01/02 08:52 PM Re: OFAC & KYC - Ins. Premium Finance


I'm so glad you said something about insurance companies. We also have an afflicated ins. co. and I just realized the USA PATRIOT Act makes them a "financial institution" too (as well as finance companies). Oh boy....... I'll have to have the Ins. board pass policies and procedures there as well.

I will appreciate any information you obtain! Thanks for your help.

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#22382 - 08/05/02 12:01 PM Re: OFAC & KYC - Ins. Premium Finance

F.Y.I. - Insurers are "financial institutions" but have been temporarily exempted from AML compliance. Treasury has indicated it is currently evaluating the horizontal and vertical insurance market. The temporary exemption expires October 24, 2002, if no specific regs are issued before then.

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