INS-TM-008Critical Risk
transaction monitoring
Red Flag
Corporate-owned life insurance (COLI) policy is purchased with company funds but the insured employees are low-level workers with no executive role, and the death benefit is disproportionate to their compensation.
Industry
Insurance Companies
Transaction Type
wire
Customer Type
business entity
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:COLI Abuse
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.