Is an insurance company required to train all of its employees in-house? What about training of brokers and agents?
An insurance company may satisfy the training requirement under its anti-money laundering program with respect to its employees, agents and brokers by directly training such persons or by verifying that those employees, agents and brokers have received adequate training by another insurance company or by a competent third party with respect to the covered products offered by the insurance company. For purposes of the rule, a competent third party can include, among others, another financial institution that is subject to an anti-money laundering program, such as a broker-dealer in securities or a bank. An insurance company remains responsible for assuring compliance with the final rule and monitoring the effectiveness of its training program. The nature of the insurance companys review of a training program performed by another entity depends upon the facts and circumstances of the particular situation. For example, if the training is performed by another entity that has its own anti-m
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