• Impact of September 11 on anti-money laundering
• USA PATRIOT Act of 2001
• Insurance regulations
• Regulation requirements

• U.S. Congress passes the USA PATRIOT Act of 2001 - Title III - International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001
• Office of Foreign Asset Control (OFAC) issues an unprecedented number of updates adding new names to the SDN list of entities and individuals linked to terrorism
• U.S. Department of the Treasury issues regulations requiring insurance companies to establish anti-money laundering programs for specified permanent life, annuity and investment products by May 2, 2006

• Significant and sweeping money laundering legislation
• Applies Anti-Money Laundering Provisions to all terrorist assets, including legally-obtained funds, if intended for use in planning, committing or concealing a terrorist act
• Mandates that all financial institutions have Anti-Money Laundering (AML) Programs
• Requires verifying identification of applicants

For insurance companies, the Anti-Money Laundering requirements apply to:

• A permanent life insurance policy, other than a group life insurance policy
• An annuity contract, other than a group annuity contract; and
• Any other insurance product with cash value or investment features

Unum "covered products":

• VWB Universal Life — VIUL, Fortune, PS 1000
• VWB Interest Sensitive Whole Life — ISWL, PS Plus
• Individual Annuities

With respect to Colonial Life and Accident Insurance Company, "covered products" include:

• All universal life policies, such as Universal Life — Policy UL 97
• All whole life policies, such as LifeBridge 96 (WholeLife) — Policy LBCDGP-96

• Development of internal polices and controls
• Designation of AML compliance officer
• Creation of employee training programs
• Independent testing of the effectiveness of the program