Ian Herbert commented on recent U.S. anti-money laundering (AML) regulatory and enforcement efforts, and what companies should do regarding compliance. "With the passage of the Anti-Money Laundering Act 2020, the Corporate Transparency Act, the recent national priorities, and the Biden administration memorandum on combatting corruption, it is clear that AML enforcement will be a well-resourced priority in the coming years," Herbert said. He added that "companies should review their anti-money laundering programs to ensure they adequately address risk."

For insurers and their agents and brokers, specifically, Herbert explained that, "insurance companies are covered entities under the Bank Secrecy Act and therefore must have an anti-money laundering program that includes adequate internal controls based on the company's assessment of anti-money laundering risk. The program should integrate the company's agents and brokers and ensure that the company obtain the relevant customer-related information necessary to combat money laundering. It should include a compliance officer, appropriate AML training, and independent testing of the program."