Because of the well-reported instances of fraud related to COVID-19 (though not necessarily insurance fraud), this seems a timely reminder to comply with SIU requirements, including training mandates. Because of the expected significant budget shortfalls all states are likely to experience in the coming months and years related to COVID-19, fines are likely to increase across the board. Don’t make it easy by having violations of this type.
Theft
Embezzlement
According to Prochoroff, the first statistics kept on SARs were from 2014. In that year, he reports a relatively small number of reasons the insurers filed SARs: structuring transactions below the Bank Secrecy Act recordkeeping thresholds: source of funds; account takeovers; identity theft; questionable automated clearing house transfers; and transactions without an apparent economic, business, or lawful purpose. SARs have been filed for those reasons in 2021 as well. But there has been a trend of additional triggers that seems to be part of the basis for the high numbers this year: forgeries; elder financial exploitation; excessive or unusual cash borrowing against a policy or an annuity; questionable or false documentation; embezzlement, theft, or disappearance of funds; suspicious use of noncash monetary instruments; suspicious use of multiple transaction locations; suspicious checks; and incidents against customers.
Drug Crimes
Money laundering hides the source of illicit funds, obscures the trail, and integrates the ‘laundered’ funds into the financial system. AML regulations have grown with the evolution of international crime organizations, corruption, terrorism, elder financial abuse, account takeover, fraud, extortion, drug trafficking, insider trading, and cybercrime. AML programs are an important tool in battling these illegal activities.
Identity Theft
Money Laundering
Whether your company is a multinational corporation or a small financial institution, a well-designed Anti-Money Laundering (AML) program should target your exposure to risks presented by your products, distribution channels, clients, services, and location(s).
[2] Even their terminology refuses to acknowledge the ubiquitous reality of electronic business transactions and the country’s dramatic move away from a paper-based work environment. Even though their own Reg 195 requires that virtually all policy form submissions are made via SERFF, an electronic platform, the outlines continually refer to the approval of paper applications. DFS never sees paper applications – they see and approve the same PDFs that they don’t allow electronic signatures on without extensive bureaucratic mandates.