INS-PEP-001Critical Risk
customer behavior
Red Flag
PEP purchases a high-value life insurance policy with premiums paid via wire from a foreign government bank account, and the coverage amount far exceeds any documented legitimate salary or assets.
Industry
Insurance Companies
Transaction Type
wire
Customer Type
PEP
Category
Regulatory Source
Document:Kleptocracy Advisory
Type:FinCEN Advisory
CFR Citation:31 CFR §1010.630
SAR Category:PEP concern
FinCEN Key Term:PEP Insurance
Last Verified:2026-04-15
This red flag is provided for informational and educational purposes only. It is not legal, regulatory, or compliance advice. Always consult the official source document and a qualified compliance professional for guidance specific to your situation.