INS-TM-005Critical Risk
transaction monitoring
Red Flag
Customer purchases a single-premium life insurance policy with a large wire transfer and requests surrender or policy loan within the free-look period, effectively using the policy as a money laundering vehicle.
Industry
Insurance Companies
Transaction Type
wire
Customer Type
individual
Category
Regulatory Source
Document:FIN-2008-G001 Insurance Red Flags
Type:FinCEN Guidance
CFR Citation:31 CFR §1025.210
SAR Category:Money laundering
FinCEN Key Term:Free-Look Surrender
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.