It is important to know your clients and recognize when their activities fall outside of the normal or expected range. Consider suspicious any transaction that appears to lack a reasonable economic basis or recognizable strategy. Be aware of activities that raise a red-flag and could indicate money laundering; some examples include, but are not limited to the following:
If you suspect or know that a transaction involves funds related to an illegal activity or is designed to avoid regulations you must report the transaction to the Senior Life Market Compliance Department. A determination as to whether a report should be filed must be based on all the facts and circumstances relating to the transaction and customer. Different fact patterns will require different judgments.
You must not notify the client. The BSA prohibits employees and agents from informing clients that their activities have been or may be reported as suspicious, that a Suspicious Activity Report (SAR) is filed, or that an ongoing investigation regarding activities in his or her account is being conducted.
"Know Your Customer" is a fundamental principle used in complying with the obligations of due diligence to decrease the possibility of you or Senior Life being used to facilitate money-laundering activities. The following information should be collected concerning the client:
The majority of clients are not involved in money laundering so it is important to be able to identify routine transactions versus suspicious transactions. A client profile provides:
Federal rules require all records maintained under AML regulations be kept five (5) years and be reasonably accessible. If a state's regulations require the records be maintained for a longer period then they must be maintained for the longer time period. As an agent, be sure to keep all customer identification you obtain in the client’s file along with any information you provided to Senior Life. By documenting your actions, you protect yourself from possible penalties.
As an agent your responsibility does not end after the initial sale. If any of your future interactions with the client seem suspicious, notify Senior Life's Market Compliance Department. Learn enough about the client’s financial goals and situation to identify if a particular transaction makes sense for the client.
Recognizing the need for a more comprehensive anti-money laundering regime to fight drug trafficking, organized crime, and international terrorism, the U.S. Congress passed and President George W. Bush signed into law the USA PATRIOT ACT (Patriot Act), which, among other things, amended the Bank Secrecy Act (BSA) to require all businesses defined in the BSA as financial institutions to implement an Anti-Money Laundering (AML) program and report suspicious transactions to the Financial Crimes Enforcement Network (FinCEN). An insurance company is defined as a "financial institution." The characteristics of financial products, including certain life insurance products, make them potentially vulnerable to those seeking to launder money. FinCEN relies upon a network of state, federal and international law enforcement agencies to collect, analyze and disseminate information about money laundering. FinCEN is also the repository for all Suspicious Activity Reports (SAR).
The BSA grants the Treasury Department the authority to require firms under its jurisdiction to develop written policies and employee training programs for compliance with the provisions of the BSA. Additionally, the reporting and recordkeeping rules within the BSA require a financial institution to:
On the heels of the terrorist attacks on September 11, 2001, the Patriot Act was signed into law to combat terrorism. The Patriot Act gives law enforcement agencies broader powers in dealing with money laundering and terrorism, and makes it more difficult for money launders to use their traditional financial channels to launder money. The Patriot Act created new anti-money laundering responsibilities for insurance companies.
Money laundering is the illegal practice of placing money gained from criminal activity, "dirty money," through a series of apparently legitimate transactions in order to hide the criminal origin of the money. The goal is to make money from criminal activity appear to be from legitimate sources. Money is usually associated with cash though non-cash transactions can play a role. Any financial transaction can be a part of the process to hide the origin of the money
Although money laundering is a diverse and often complex process, it basically involves three independent steps that can occur simultaneously, separately or overlap.
Penalties for money laundering can be severe. Fines could be twice the amount of the transaction up to 1 million dollars. Any property involved in the transaction or traceable to the proceeds of the criminal activity may be subject to forfeiture. Individuals are subject to prison terms for being willfully blind to the fact that the transaction involved illegal funds. In addition, insurance companies risk losing their charter, and agents risk being removed and barred from insurance. Insurance companies have their own disciplinary policies and procedures.
Agents not complying could be subject to disciplinary action up to and including termination and will be reported to the proper legal authorities. To protect yourself from a willful blindness charge:
One of the most harmful outcomes from involvement in a money laundering investigation is damage to the agent and insurance company's reputation. Being aware of and following money laundering requirements helps protect our most valuable sales tool, your reputation.
Dr. Nathanial Hearne, epitomizes what “up by the bootstraps” stands for. An educator, motivator, mentor, executive, Pastor, trainer…and ultimately… the man who has led countless individuals to excel far past their expectations and even their dreams. He was instrumental in combining education with athletics much to the chagrin of some coaches while earning him the love and respect of those he molded into men.
Dr. Hearne played an important part in the lives of those football players and coaches who the film, “Friday Night Lights” was all about. As Assistant Coach he instilled a love of honor and sportsmanship in every team member as he led them in strength and stamina conditioning. The Permian High School team became National Football Champions in 1989 and State Champs in 1991.
As Assistant Principal and then Principal in the Hurst-Euless-Bedford ISD of Texas, he turned around the Discipline Alternative Education Program for difficult students managing it for five years… and motivating hundreds of potential drop-outs to remain in school and graduate.
His Dropout Prevention Program was recognized by the “Texas School Business” magazine as the best prevention program in Texas in 2010. Dr. Hearne practiced what he preached, that by applying yourself and making the most of what God had blessed you with you could do anything and become anything you wanted.
One of eight children raised by strong parents, he excelled in school. But, like those he came to mentor, he didn’t like school and wanted to drop out. He says you didn’t argue with a mom who held two jobs to clothe and feed you… you did what she told you to do. His first degree was a B.S. in Physical Education at North Texas State University in 1974. He returned to the University of Texas in 1979, obtaining a Master of Arts. In 1998 he garnered a Master of Divinity at SMU while working full time at the Clarksville ISD as the Football Defensive Coordinator and Condition Coach. The next year he became an Ordained Minister and served as such in several churches. In 2009 he was back at SMU obtaining a Doctor of Ministry.
Dr. Hearne’s ultimate, all time, challenge and success has been his dynamic presentations on “Leaving a Legacy” that will have you cheering one minute and crying the next. Click here to watch.
He is happily married to Callie & resides in Arlington, Texas. They have five grown children and three grandchildren.
International business coach, #1 Amazon.com best-selling author and favorite conference speaker, Howard Partridge grew up on welfare, started his first business out of the trunk of his car and transformed it into a multi-million dollar, turnkey enterprise.
He has owned nine small businesses and for two decades he has helped small business owners revolutionize their businesses and have more freedom in their lives.
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