Time to Update Property & Casualty Exemption from Money Laundering Rules

Photo by Christine Roy on Unsplash

FinCEN’s BSA Exemption should Modernize and Reflect Captive Insurance Risks

Treasury’s Financial Crime Enforcement Network (FinCEN) recently sought information and comment on how to improve existing Bank Secrecy Act regulations and guidance.

Bank Secrecy Act regulations provide that “each insurance company shall develop and implement a written anti-money laundering program applicable to its covered products.”

CBI’s Comments to FinCEN are available here.

In response to this request for information and comment, CBI draws FinCEN’s attention to a few “rough edges” in the exemption afforded property and casualty insurance products under current Bank Secrecy Act (BSA) guidance.

Specifically, FinCEN’s current guidance on the exemption for property and casualty insurance:

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