Anti-Money Laundering (AML): Expectations for Insurance Producers

,

As financial crime methods continue to evolve, insurance products — particularly those with cash value or investment components — remain attractive vehicles for money laundering and terrorist financing. We want to remind you of your AML obligations and outline emerging risks and regulatory expectations in the insurance sector.

Key risks in insurance products

Insurance producers should be especially alert to AML risk in the following products:

  • Annuities (especially single premium immediate and variable annuities)
  • Life insurance with high cash value
  • Any insurance product with early contract surrenders or overfunded premiums
  • Any insurance product with third-party premium payments or offshore clients

Bad actors may attempt to use insurance products to:

  • Introduce illicit funds into the financial system
  • Layer transactions to obscure the origin of funds
  • Extract funds through policy loans or early surrenders

Regulatory & internal expectations

All producers are expected to follow regulatory obligations and our internal AML Program requirements, which includes:

1. Customer Due Diligence (CDD)

  • Verify the identity of all contract holders and beneficiaries
  • Escalate any inconsistencies in customer information to Athene’s AML compliance team.
  • Understand the customer’s source of funds and purpose of the contract

2. Suspicious Activity Reporting

  • Be alert to red flags such as unusual payment methods, reluctance to provide information, or high-risk jurisdictions.
  • Promptly escalate potential suspicious activity to our AML Compliance team.
  • Do not inform the customer if a report has been filed (non-disclosure obligations).

3. Ongoing Monitoring

  • Monitor contract activity post-sale for signs of structuring, layering, or abnormal withdrawals.
  • Conduct periodic risk reviews on higher-risk clients and policies.

4. Training & Awareness

  • Complete the required annual AML training
  • Stay informed about evolving typologies and AML best practices
  • Ask questions or escalate concerns — proactive engagement is critical

File a report

When you suspect money laundering, please complete the Request for Compliance Review form or report the event to our Compliance department by emailing us at AMLFraudReferral@athene.com.

Questions or concerns?

For additional guidance, please refer to the Producer’s Guide to Anti-Money Laundering and the Doing Business with Athene Producer Guide (19608).

Compliance is a shared responsibility. Stay vigilant. Stay compliant.