UNUM
USA Patriot Act
Compliance Program
Anti-Money
Laundering
Policy
Table of Contents
1.0
INTRODUCTION
1.1 Ownership
1.2 Anti-Money Laundering Compliance Officer
1.3 Purpose of Policy
2.0
MONEY LAUNDERING
2.1 Money Laundering Process
2.2 Individual Employee Duties
3.0
INSURING COMPANIES
3.1 Product and Service Risk Assessment
3.2 Know Your Customer Guidelines
3.3 Red Flags
4.0
OTHER BUSINESS RELATIONSHIPS
5.0
REPORTING
5.1 Suspicious Activity Report
5.2 Monitoring for Suspicious Activity
5.3 Confidentiality
6.0
TRAINING
7.0
RECORDKEEPING REQUIREMENTS
8.0
SELF-ASSESSMENT
Exhibit A Risk Assessment Guidelines and Results of
Product and Portfolio Service Review
Exhibit B Know Your Customer Guidelines
Exhibit C Suspicious Transaction Guidelines - Red Flags
Exhibit D Suspicious Activity Report (SAR) Worksheet
Anti-Money Laundering Policy
Effective Date: May 2, 2006
Page 1
1.0 INTRODUCTION
The attempted use of financial institutions to launder money is a significant
problem that has resulted in the passage of stricter laws and increased
penalties for money laundering including the USA Patriot Act. This Anti-
Money Laundering Policy (“Policy”) is designed to establish principles and
standards to protect against attempts at laundering money through Unum
Group and its United States subsidiaries (“Unum”).
This Policy is to be used to create an understanding among employees
concerning the risks of laundering money and the penalties for failing to
comply with the procedures outlined herein. This Policy establishes the
minimum standards to which Unum must adhere. In any case where the
requirements of applicable anti-money laundering laws establish higher
standards, Unum will adhere to those laws. Implementation of the Unum
Anti-Money Laundering Program is predicated upon a careful analysis of the
final rules for insurance companies issued by the U.S. Treasury Department,
assessment of the vulnerabilities of our business to money laundering,