INSURANCE ANTI-MONEY LAUNDERING (AML) COMPLIANCE CHECKLIST

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--- CUSTOMER IDENTIFICATION PROGRAM (CIP) ---
[ ] Customer Name
[ ] Customer Type (Individual/Business) (Individual, Business)
[ ] Residential/Business Address
[ ] Date of Birth (for Individuals)
[ ] Tax Identification Number (TIN)
[ ] Proof of Identity (e.g., Passport, Driver's License)
[ ] Proof of Address (e.g., Utility Bill, Bank Statement)

--- TRANSACTION MONITORING ---
[ ] Transaction Amount
[ ] Transaction Date
[ ] Transaction Type (Premium Payment, Claims Payment, Investment Transfer, Other)
[ ] Description of Transaction
[ ] Payment Method (Wire Transfer, Check, Credit/Debit Card, Electronic Funds Transfer (EFT))
[ ] Policy Number
[ ] Flags for Review (Select all that apply) (Large Sum, Unusual Recipient, Frequent Transfers, New Account)

--- SANCTIONS SCREENING ---
[ ] Customer Name
[ ] Customer Address
[ ] Beneficiary Name (if applicable)
[ ] Sanctions List Used (e.g., OFAC, EU, UN) (OFAC, EU, UN, Other - Specify)
[ ] Matching Entities Found (check all that apply) (No Matches, Partial Match - Investigate, Exact Match - Block Transaction)
[ ] Sanctions Screening Date
[ ] Investigator Initials

--- POLITICALLY EXPOSED PERSONS (PEP) SCREENING ---
[ ] PEP Status (Not PEP, Potential PEP, Confirmed PEP)
[ ] Name of PEP (if applicable)
[ ] Relationship to Customer (if applicable)
[ ] Date PEP Status Determined
[ ] Geographic Risk Level (Country of Association) (Low, Medium, High)
[ ] Position/Title of PEP (if applicable)
[ ] Enhanced Due Diligence (EDD) Notes
[ ] EDD Approval Status (Pending, Approved, Rejected)

--- RECORD KEEPING ---
[ ] Record Creation Date
[ ] Summary of Transaction Details
[ ] Supporting Documentation (e.g., ID verification, transaction records)
[ ] Transaction Amount
[ ] Record Type (New Customer, Existing Customer, Suspicious Activity Report)
[ ] Record Identifier/Tracking Number

--- EMPLOYEE TRAINING ---
[ ] Training Completion Date
[ ] Training Module Completed (CIP Fundamentals, Transaction Monitoring, Sanctions Screening, Reporting Procedures)
[ ] Quiz Score (%)
[ ] Employee Comments / Feedback
[ ] Training Format (Online Module, Classroom Training, Webinar)
[ ] Proof of Completion (Certificate/Record)

--- REPORTING SUSPICIOUS ACTIVITY ---
[ ] Detailed Description of Suspicious Activity
[ ] Estimated Value of Transaction(s)
[ ] Suspected Crime Type (Money Laundering, Fraud, Terrorist Financing, Other)
[ ] Relevant Parties Involved (Policyholder, Agent, Third Party, Beneficiary)
[ ] Date of Suspicious Activity
[ ] Time of Activity
[ ] Reporting Channel (Internal Compliance Team, Law Enforcement Agency, FinCEN)

--- RISK ASSESSMENT ---
[ ] Estimated Transaction Volume (Annual)
[ ] Primary AML Risk Factor(s) (Complex Ownership Structures, High-Value Transactions, Geographic Location (High-Risk Country), Product Complexity, Customer Type (e.g., Businesses))
[ ] Description of Current AML Risk Mitigation Strategies
[ ] Date of Last Risk Assessment
[ ] Risk Level (Overall) (Low, Medium, High)
[ ] Supporting Documentation (Risk Assessment Report)

--- POLICY AND PROCEDURES REVIEW ---
[ ] Last Review Date
[ ] Summary of Changes Made
[ ] Review Frequency (Annually, Bi-Annually, As Needed)
[ ] Version Number
[ ] Supporting Documentation
[ ] Reviewer Name

--- INDEPENDENT TESTING ---
[ ] Date of Independent Test
[ ] Type of Test Performed (Process Review, System Audit, Data Analysis, Compliance Walkthrough)
[ ] Number of Transactions Reviewed
[ ] Summary of Testing Methodology
[ ] Areas Tested (CIP, Transaction Monitoring, Sanctions Screening, Reporting)
[ ] Findings/Deficiencies Identified
[ ] Recommendations for Remediation
[ ] Tester Signature

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