In order to sell most life insurance and annuity products, you need to complete Anti-Money Laundering (AML) training.
AML training teaches you about the process of money laundering, the laws that make it a crime, and your responsibility to detect and stop it from happening.
The Life Insurance Marketing and Research Association (LIMRA) offers free AML training through their website. That's what I use as a producing agent, and it's what I recommend to other agents. There are other options out there like WebCE, but LIMRA is free and easy.
Why Should I Care About Money Laundering?
According to the United Nations Office on Drugs and Crime, the estimated amount of money laundered each year is 2-5% of the global GDP, or $800 billion-$2 trillion.
Money laundering is typically linked to:
- Drug trafficking
- Prostitution rings
- Insider trading
- Bribery and computer fraud schemes
- Illegal arms sales
When criminals find ways to generate a substantial profit, they need a way to control that money without attracting attention to how they got it. They do this by disguising the sources, changing the form, or moving the funds to a place where they're less likely to attract attention (Financial Action Task Force).
And sometimes, these criminals use insurance products, like permanent life insurance or annuities. That's where AML training comes in for the individual producer.
Why Do I Need AML Training?
The U.S. Securities and Exchange Commission (SEC) explains that Section 352 of the USA Patriot Act requires financial institutions, including broker-dealers, to establish AML programs. The USA Patriot Act defines insurance companies as financial institutions.
In other words, insurance companies are required, by law, to establish anti-money laundering programs. However, not all insurance companies have to do this – just those with products that are considered high-risk for money laundering.
The Department of the Treasury Financial Crimes Enforcement Network explains that some insurance products are "potentially vulnerable" to those seeking to launder money.
Those "risky" and "vulnerable" products include:
- Permanent life insurance policies (other than a group life policy)
- An annuity contract (other than a group contract)
- Any other insurance product with cash value or investment features
Now, insurance agents aren't required to establish an anti-money laundering program. Rather, each insurance company is required to integrate its agents and brokers into its anti-money laundering program, and they have to monitor your compliance with the program.
So, to bring it all together: if an insurance company offers permanent life insurance, annuities, or any product with cash value or investment features, you need to complete AML training to sell it.
You don't need AML training for group insurance products, products offered by charitable organizations (like charitable annuities), term life insurance, property and casualty insurance, health insurance, and other kinds of insurance that don't exhibit these risky features (NAIC).
The insurance company is ultimately responsible for ensuring its products aren't being used to launder money. That's why you have to complete AML training in order to get contracted with certain carriers.
That's also why you have to meet ongoing training requirements via an annual refresher course.
When you use LIMRA for the AML training, you complete the core training once. Once you've done the initial core training, you're only required to do the annual refresher course.
The annual refresher courses focus on specific topics covered in the initial AML training course. For example, a recent course focused in on "willfull blindness," or turning a blind eye to suspicious activity that could indicate money-laundering.
What You'll Learn In AML Training
As a producer, you'll be coached on red flags and suspicious activity indicators.
Some examples include:
- Customer shows little or no concern for the investment performance of the product, but a great deal of interest about the early termination features and seems to be knowledgeable about early surrender, loans, withdrawals, and free look periods
- Customer is reluctant to provide identifying information when purchasing the product, provides minimal or seemingly fictitious information
- Customer uses a deceased person’s social security number or provides information that is inconsistent or appears suspicious
- Customer does not want to meet agent at residence or place of employment or who wants to meet during odd hours
- Customer pays initial premium with checks or wire transfers from the account of an unrelated (NOT the Owner, Payor, or Insured) third party
- Customer applies for policy from a distant location when comparable coverage can be obtained closer to home
- Customer accepts unfavorable underwriting conditions for his age or health
- Customer does not ask how much the product will cost, does not want to compare products based upon cost/benefit ratio and may offer to pay higher premium for speed and other accommodations
- Customer presents unusual or suspect personal or business identification documents
- Customer questions whether government report will be filed based upon transaction
- Customer has criminal record or is publicly associated with known felons
- Customer, their family, or close associates, are senior foreign political officials
- Customer asks for details about or exception to policies/procedures that deter money laundering
- Applicant buys policies from several insurers in a short period of time
- Customer has accounts in country identified as a tax haven
Examples of tax haven countries include Costa Rica, Cayman Islands, Monaco, Panama, St. Kitts, and Switzerland.
I personally don't prep or study for the AML training, but this gives you a good idea of what's involved.
Carriers That Require AML Training
All life and annuity carriers require AML training.
The life insurance carriers we represent that will require AML training include:
- Banner Life
- Gerber Life
- John Hancock
- KSKJ Life
- Mutual of Omaha
- Oxford Life
The annuity carriers we represent that will require AML training include:
- American Equity
- Atlantic Coast Life
- EquiTrust Life
- Fidelity & Guaranty
- Great American
- Guaranty Income Life Insurance Company (GILICO)
- Investors Heritage
- Liberty Bankers Life
- North American Company
- Ohio State Life
- Royal Neighbors of America
- Upstream Life
- Western United Life Assurance Company (WULA)
Not all final expense carriers we represent require AML training. For example, Foresters requires it, while Accendo/CVS Health does not. Our contracting department will let you know if your requested carrier requires AML training.
LIMRA does not provide certificates of completion to the individual user. Completion certification is validated by LIMRA and reported electronically to the requesting company.
Complete Your AML Training & Test
When you're ready to take the AML training, you'll log in to the AML Training Program.
You're required to access every web page and answer quiz questions to complete the course.
You're allowed to leave and re-enter the site at any time during the training. You can also log back in after you're done if you need to reference any of the training materials.
The training takes about 30 minutes to complete, and it's really nothing to worry about!
AML training is easy, and if you complete it through LIMRA, it's free. You'll learn everything you need to know about money laundering, the laws surrounding it, and how you can help stop these criminals from legitimizing their profits.
AML training might seem like another annoying box to check off on your annual to-do list, but it's a pretty good feeling knowing you could stop a criminal running a sex trafficking scheme, for example.
If you need any help getting the AML training squared away, contact us! You can give us a call at 888-780-7676 or use the website chat feature during regular business hours (8am-4:30pm CT).