Are insurance companies required to file Suspicious Activity Reports as a part of their anti-money laundering programs?
Yes. Pursuant to a final rule adopted at the same time as the anti-money laundering program final rule, insurance companies will now be required to file Suspicious Activity Reports. This requirement will take effect 180 days from when the final rule is published in the Federal Register. We have proposed a new suspicious activity reporting form for insurance companies (FinCEN Form 108 Suspicious Activity Report by Insurance Companies). Until such time as that form has been adopted and is available for use, insurance companies should use FinCEN Form 101 Suspicious Activity Report by Securities and Futures Industries to report suspicious transactions. Importantly, to assist law enforcement in locating reports filed by insurance companies, the words Insurance SAR should be entered on the first line of the Narrative. Under the final rule requiring suspicious activity reporting by insurance companies, covered insurance companies must file Suspicious Activity Reports to report suspicious tran
