Our Bank has a Division that performs the following personal insurance activity:

At the request of a customer <?>, the Divison solicits competitive policy bids from various insurance companies. Bids are evaluated with the customer and an insurance company is selected. Upon placement with the Insurance company, the Division receives a commission from the Insurance company.

As best I can tell we don't need to CIP these persons as the relationship is with the Insurance Co. (sound right??)But I am NOT as certain that our Bank is not responsible for other aspects of BSA/AML.

Do you think that the Divsion has any BSA/AML responsibilities after they the person is placed with the insurance company? How about OFAC?