INS-TM-002High Risk
transaction monitoring
Red Flag
Customer pays premiums using sequentially numbered checks from multiple unrelated bank accounts, suggesting the policy is being funded by a network of nominees or shell accounts.
Industry
Insurance Companies
Transaction Type
check
Customer Type
individual
Category
Regulatory Source
Document:FIN-2008-G001 Insurance Red Flags
Type:FinCEN Guidance
CFR Citation:31 CFR §1025.210
SAR Category:Suspicious activity
FinCEN Key Term:Nominee Checks
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.