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Anti-Money Laundering for Insurance

BSA/AML compliance for insurance producers. Suspicious activity recognition, SAR filing, and insurance-specific money laundering schemes.

6 Units
20 minutes per unit
Curriculum Map

What You Will Learn

Insurance Schemes

How money laundering manifests in insurance — single-premium purchases, surrenders, and shell entities.

CDD & Beneficial Ownership

Customer due diligence requirements and beneficial ownership identification for insurance transactions.

SAR Filing

When and how to file Suspicious Activity Reports — the obligations specific to insurance producers.

All Units

1
20 minutes
BSA/AML Framework for Insurance
This unit examines the Bank Secrecy Act and anti-money laundering regulatory framework as applied to insurance companies, including covered products, regulatory authority, and the unique compliance challenges arising from insurance industry characteristics.
  • •Explain the statutory and regulatory framework applying BSA/AML requirements to insurance companies
  • •Identify which insurance products and business lines trigger BSA/AML compliance obligations
  • •Describe the intersection of state insurance regulation and federal anti-money laundering enforcement
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2
20 minutes
Insurance-Specific Money Laundering Schemes
This unit examines specific money laundering schemes targeting insurance products, including policy cycling, early surrender patterns, third-party premium payments, and complex ownership structures used to obscure the origin of illicit funds.
  • •Identify common money laundering typologies exploiting life insurance and annuity products
  • •Recognize policy churning, early surrender, and premium financing patterns indicative of illicit activity
  • •Explain how insurance products facilitate the placement, layering, and integration stages of money laundering
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3
20 minutes
Customer Due Diligence & Beneficial Ownership
This unit examines customer due diligence obligations for insurance companies, including customer identification, beneficial ownership rules for legal entities, risk-based verification procedures, and ongoing monitoring requirements to detect suspicious activity.
  • •Explain the customer due diligence requirements under FinCEN's Customer Due Diligence Rule
  • •Apply beneficial ownership identification procedures for legal entity customers
  • •Implement risk-based customer verification and ongoing monitoring procedures appropriate to insurance products
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4
20 minutes
SAR Filing Obligations & Procedures
This unit examines Suspicious Activity Report filing obligations for insurance companies, including filing thresholds and triggers, the SAR filing process, required documentation, confidentiality protections, and enforcement consequences for non-compliance.
  • •Identify the circumstances triggering mandatory Suspicious Activity Report filing for insurance companies
  • •Apply the SAR filing timeline, documentation, and confidentiality requirements under 31 CFR § 1025.320
  • •Explain the consequences of failing to file required SARs and the protections afforded to filers
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5
20 minutes
Red Flags & Suspicious Activity Recognition
This unit provides practical guidance on recognizing red flags in insurance transactions, including customer behavior patterns, transaction characteristics, documentation anomalies, and contextual factors that should trigger enhanced scrutiny and potential SAR filing.
  • •Identify common red flag indicators of money laundering in insurance transactions
  • •Apply pattern recognition techniques to distinguish suspicious behavior from legitimate complex transactions
  • •Develop escalation protocols for front-line insurance personnel encountering red flags
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6
20 minutes
Building an AML Compliance Program
This unit provides a framework for building and maintaining an effective AML compliance program for insurance companies, including required program elements, governance structures, risk assessment methodologies, and continuous improvement processes.
  • •Design the four required components of an insurance company AML compliance program under 31 CFR § 1025.210
  • •Develop risk-based policies and procedures appropriate to the insurer's product mix and distribution model
  • •Implement effective training, testing, and independent audit functions for AML program oversight
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Continuing education for financial services professionals. 2 credit hours (Insurance Compliance). Accepted for CFPs, IARs, and insurance producers.