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FC-5.1.1

An insurance licensee must take reasonable steps to provide periodic training and information to ensure that staff who handle customer transactions, or are managerially responsible for such transactions, are made aware of:

(a) Their responsibilities under the AML Law, this Module, and any other relevant AML/CFT laws and Regulations;
(b) The identity and responsibilities of the MLRO and his deputy;
(c) The potential consequences, both individual and corporate, of any breach of the AML Law, this Module and any other relevant AML/CFT laws or Regulations;
(d) The insurance licensee's current AML/CFT policies and procedures;
(e) Money laundering and terrorist financing typologies and trends;
(f) The type of customer activity or transaction that may justify an internal STR;
(g) The insurance licensee's procedures for making internal STRs; and
(h) Customer due diligence measures with respect to establishing business relations with customers.
Amended: January 2007