You must notify Genworth if you detect any money laundering red flags, such as:
- The purchase of a product that appears to be inconsistent with a customer's needs or exhibits lack of concern regarding investment risk
- Little or no concern by a customer for the investment performance of an insurance product, but much concern about the early termination features of the product
- Customer reluctant to provide identifying information, or the provision of information that seems fictitious
- Customer is unusually curious about compliance procedures
- Policy/contract owner and/or insured focus on the administrative aspects of procedures versus the purchase itself
- Policy/contract owner purchases multiple policies where insured/annuitant differs on each of the policies/contracts
- Policy/contract owner and/or insured/annuitant has a recent substantial change in financial history, or
- Any other activity that you reasonably believe may be suspicious.
There are certain types of customers who may pose a higher risk of engaging in money laundering activities, and for whom additional due diligence is required. The producer, general agent or consumer may be contacted if the issuing company requires additional information. These types of customers include but are not limited to:
- Non-resident aliens or foreign customers
- Customers who resist providing identifying information
- Senior foreign political figures and their immediate family members
- Certain non-governmental organizations or charities
If you detect red flag or suspicious activity, you must notify Genworth.