It's not so long ago that the authorities in the USA mistakenly claimed that insurance should be regarded as low risk and therefore should have a "light touch" regime. Then the Final Rule came out, and provided loopholes that rendered the insurance industry highly attractive to money launderers. FinCEN has issued some guidance. Is it any help?
The latest guidance is an update of guidance originally issued in 2005. The full guidance is available in WMLRO: Resources.
World Money Laundering Report Volume 8 No 6 will have an analysis of the value of the guidance.