AML/KYC Program
Comprehensive anti-money laundering and know-your-customer program designed to prevent financial crimes, comply with Bank Secrecy Act requirements, and meet insurance regulatory standards for customer identification and verification.
Program Statement
Daily Event Insurance maintains a risk-based Anti-Money Laundering (AML) program that includes Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), ongoing transaction monitoring, and suspicious activity reporting. Our program is designed to comply with the Bank Secrecy Act, USA PATRIOT Act, and applicable insurance regulations.
KYC Verification Levels
Risk-based approach with escalating verification requirements based on risk indicators.
Basic
All customers
Standard
Partners, high-value policies
Enhanced
High-risk indicators, large transactions
Full
PEP, sanctions concerns
Customer Identification Program (CIP)
Required information collected and verified for each customer type per USA PATRIOT Act Section 326.
Individual Customers
- Full legal name
- Date of birth
- Address (residential or business)
- Identification number (SSN or foreign equivalent)
Documentary (ID) or non-documentary (database verification)
Business Customers
- Legal business name
- Principal place of business
- EIN or equivalent tax ID
- State of incorporation/registration
Secretary of State records, business documents
Beneficial Owners
- Names of individuals with 25%+ ownership
- Names of controlling person(s)
- Same info as individual customers
Certification form plus verification
Transaction Monitoring Rules
Automated monitoring rules to detect suspicious activity patterns and regulatory thresholds.
| Rule ID | Rule Name | Trigger | Action | Severity |
|---|---|---|---|---|
| TM-001 | High Value Transaction | Single transaction > $10,000 | Flag for review, potential CTR filing | high |
| TM-002 | Velocity Alert | 5+ transactions in 24 hours | Review for structuring patterns | medium |
| TM-003 | Daily Volume Threshold | Cumulative daily > $25,000 | Enhanced monitoring, potential SAR | high |
| TM-004 | Weekly Volume Threshold | Cumulative weekly > $100,000 | Review by compliance officer | high |
| TM-005 | Geographic Risk | High-risk jurisdiction indicators | Enhanced due diligence | medium |
| TM-006 | Structuring Pattern | Multiple transactions just under $10,000 | Immediate SAR consideration | critical |
| TM-007 | Unusual Activity | Deviation from established patterns | Investigation, documentation | medium |
| TM-008 | Sanctions Match | Name/entity matches OFAC list | Transaction block, immediate escalation | critical |
AML Alert Types
High Value Transaction
Single transaction exceeds $10,000
Unusual Pattern
Activity deviates from established baseline
Velocity Exceeded
Transaction frequency exceeds thresholds
Sanctioned Party
Match against OFAC or other sanctions lists
PEP Match
Politically exposed person identification
Structuring Suspected
Pattern suggests avoiding reporting thresholds
Sanctions Screening (OFAC Compliance)
All customers and transactions are screened against OFAC sanctions lists in real-time. Matches result in immediate transaction blocking and compliance review.
Lists Screened
- Specially Designated Nationals (SDN)
- Sectoral Sanctions Identifications (SSI)
- Foreign Sanctions Evaders (FSE)
- Non-SDN Menu-Based Sanctions (NS-MBS)
- Consolidated Screening List
Screening Process
- 1Real-time screening at onboarding
- 2Batch rescreening on list updates
- 3Transaction-level screening
- 4False positive review (2-hour SLA)
- 5True match escalation (immediate)
Suspicious Activity Reporting (SAR)
Process for identifying, investigating, and reporting suspicious activity to FinCEN.
Suspicious activity identified through monitoring or report
Compliance team reviews activity, gathers documentation
Compliance officer determines if SAR is warranted
SAR filed with FinCEN via BSA E-Filing system
Supporting documentation retained for 5 years
SAR Confidentiality
The existence of a SAR is confidential. It is a federal crime to disclose to any person involved in the transaction that a SAR has been filed. SARs must not be discussed with customers, and documentation must be maintained separately from customer files.
Risk Assessment Framework
Customer Risk
- Type of customer (individual vs. business)
- Geographic location
- Occupation or business type
- Source of funds
- PEP status
Product Risk
- Policy type and coverage amount
- Payment methods used
- Frequency of transactions
- Premium amounts
Geographic Risk
- Customer location
- Event location
- Connection to high-risk jurisdictions
- Cross-border transactions
Transactional Risk
- Transaction size and frequency
- Payment patterns
- Cash vs. electronic payments
- Third-party payments
AML Training Program
Initial Training
All employees within 30 days of hire
Annual Refresher
Required for all staff annually
Role-Based Training
Advanced training for compliance staff
Topics Covered
- • BSA/AML regulatory requirements
- • Red flags and suspicious activity indicators
- • CIP and CDD procedures
- • SAR filing requirements
- • OFAC sanctions compliance
- • Record retention requirements
Documentation
- • Training attendance records
- • Comprehension assessments
- • Training materials archived
- • Certificates of completion
- • Records retained 5 years
AML Compliance Officer
A designated AML Compliance Officer has overall responsibility for the AML program, including: