Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Programs for Insurance Companies, Loan or Finance Companies, and Banks Lacking a Federal Functional Regulator

31 U.S.C. 5318(h)(1) of the BSA mandates that financial institutions establish AML/CFT programs to guard against money laundering and the financing of terrorism. Such programs must include, at a minimum: (a) the development of internal policies, procedures, and controls, (b) the designation of a compliance officer, (c) an ongoing employee training program, and (d) an independent audit function to test programs. Pursuant to 31 U.S.C. 5318(h)(2), FinCEN issued regulations requiring banks lacking a Federal functional regulator (31 CFR 1020.210(b)), money services businesses (MSBs) (31 CFR 1022.210), mutual funds (31 CFR 1024.210), insurance companies (31 CFR 1025.210), dealers in precious metals, precious stones, or jewels (31 CFR 1027.210), operators of credit card systems (31 CFR 1028.210), and loan or finance companies (31 CFR 1029.210) to develop and implement written AML programs. This supporting statement covers the AML program requirements for insurance companies, loan and finance companies, and banks lacking a Federal function regulator.

The latest form for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Programs for Insurance Companies, Loan or Finance Companies, and Banks Lacking a Federal Functional Regulator expires 2027-09-30 and can be found here.