When insurance subsidiary operations is brought into the bank as a department is the bank responsible for performing CIP on these customers or is it the responsibility of the insurance carrier issuing the policy? Customer deals with the bank's licensed agents and has no contact with the carrier.

I recently went to a seminar and this topic was discussed. The ins company is the one who has CIP/AML duties; however the ins co can delegate to the agent these duties. The agent is in the best position to CIP and look for money laundering.