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The Financial Crimes Enforcement Network has unveiled a draft of a form that life insurance companies might end up using to report suspicious transactions to regulators.[@@]

FinCEN, an arm of the U.S. Treasury Department, has posted a proposed version of the form, Form 108 – Suspicious Activity Report by Insurance Companies, on the Web at //

FinCEN officials estimate in a discussion of the form that about 1,200 companies will spend about 2 hours each reporting about 1,200 transactions that may have something to do with efforts to launder money associated with terrorism, drug trafficking or other illegal activities.

The 2-page form comes with 4 pages of instructions.

Question 23, which deals with “suspicious activity that can be identified,” includes boxes for clues such as “bribery/gratuity,” “little or no performance concern,” “identity theft” and “unusual viatical sales.”

In the instructions, FinCEN emphasizes in bold type that“the reporting financial institution should not include legal disclaimers in the narrative” description of the suspicious activity.

FinCEN also warns insurers filling out the form that federal law forbids them from notifying any person involved in the transaction being reported about the report.

Public comments about the draft form are due Jan. 3, 2006.


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