Essentially, insurance companies that are affected by the rule will have only six months
to establish and implement their anti-money laundering programs. In placing the AML Program responsibility on insurance companies, FinCEN clarified its position that insurance companies were better prepared and able to take responsibility for the anti-money laundering programs, than brokers and agents. Therefore, the insurance
companies will have to assume all responsibilities for the programs, including integrating
its agents and brokers into the program, and the customer identification process.

Not all insurance companies are required to have an AML Program under the rule; only those insurance companies that issue or underwrite covered insurance products as a business. Under the rule, covered insurance products include permanent life insurance (other than a group life insurance policy), any annuity contract (other than a group annuity contract) and/or any insurance product with investment or cash value features. Insurance companies that offer exclusively other types of products, casualty and property insurance
for example, will not be required to implement an AML Program.