Guggenheim Life and Annuity Company

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1 Guggenheim Life and Annuity Company ANTI-MONEY LAUNDERING POLICY AND PROCEDURES EFFECTIVE: JULY, 2015 AML POLICY 07/ PHONE FACSIMILE PAGE 1 OF 18

2 Anti-Money Laundering Policy and Procedures Contents Definitions... 3 Statement of Policy and Procedures... 4 Training... 8 Independent Audit... 9 Monitoring and Reporting... 9 Procedures Civil and Criminal Penalties Updates, Modifications and Exceptions Information Sharing with Law Enforcement and Supervisory Authorities Appendix A Anti-Money Laundering Compliance Officers Appendix B Anti-Money Laundering Compliance Committee Exhibit A Suspicious Activities Guidance Red Flags Exhibit B Guggenheim Internal Form 101 Suspicious Activity Report ( SAR ) Exhibit C - Customer Identification Program Notice AML POLICY 07/ PHONE FACSIMILE PAGE 2 OF 18

3 Definitions MONEY LAUNDERING Money Laundering is engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages: placement, layering and integration. PLACEMENT Placement is the first stage of money laundering where cash first enters the financial system. Cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler s checks or deposited into accounts at financial institutions. LAYERING Layering is the second stage of money laundering where funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. INTEGRATION Integration is the third stage of money laundering where the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. SENIOR FOREIGN POLITICAL OFFICIAL Senior Foreign Political Officials are the senior officials in the executive, legislative, administrative, military or judicial branches of a foreign government, a senior official of a major foreign political party, a senior executive of a foreign government-owned corporation, or any corporation, business, or other entity that has been formed by, or for the benefit of, one or more senior foreign political figures. CRITICAL INFRASTRUCTURE PROTECTION The Office of Critical Infrastructure Protection ( CIP ) and Compliance Policy coordinates the development and implementation of policies regarding: the protection of the critical infrastructure of the financial services sector, including the Department's lead agency role with respect to the financial sector; the development of statutes and regulations within the financial sector, including money laundering, internet gambling and identity theft; and the sharing of information among financial institutions and between the private and public sectors, including financial privacy and the sharing of suspicious information pursuant to the Bank Secrecy Act. LIMRA LIMRA International is a worldwide association providing research, consulting, and other services to nearly 850 insurance and financial services companies in more than 60 countries. LIMRA was established in 1916 to help its member companies maximize their marketing effectiveness. OFAC - OFFICE OF FOREIGN ASSETS CONTROL The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries, terrorists, international narcotics traffickers and those engaged in activities related to the proliferation of weapons of mass destruction. OFAC acts under Presidential wartime and national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze foreign assets under U.S. jurisdiction. AML POLICY 07/ PHONE FACSIMILE PAGE 3 OF 18

4 FOREIGN SHELL BANK Refers to an offshore bank without a physical presence in any country. HIGH RISK JURISDICTIONS Link to List of High Risk Jurisdictions This list includes: (i) countries subject to OFAC sanctions, including state sponsors of terrorism; (ii) countries identified as supporting international terrorism under section 6(j) of the Export Administration Act of 1979, as determined by the US Secretary of State; (iii) jurisdictions determined to be of primary money laundering concern by the U.S. Treasury Department; (iv) jurisdictions or countries identified as non-cooperative by the Financial Action Task Force on Money Laundering; and (v) the twenty countries ranked with the highest risk in Transparency International s Corruption Perceptions Index. LEGAL AND REGULATORY ACTIONS Include: (i) a felony criminal conviction; (ii) an expulsion or current suspension from membership or participation in a selfregulatory organization (e.g., FINRA, MSRB) or the foreign equivalent of a self-regulatory organization, or a domestic or foreign securities or futures exchange; (iii) a bar or current suspension imposed by the Securities and Exchange Commission ( SEC ) or other self-regulatory organization or foreign financial regulatory authority; (iv) a denial or revocation of registration by the SEC, the Commodity Futures Trading Commission ( CFTC ), or a foreign financial regulatory authority; or (v) a finding that a member or person associated with a member has made false statements in applications or reports made to, or in proceedings before, a self-regulatory organization. Statement of Policy and Procedures Guggenheim Life and Annuity Company and its affiliates, Clear Spring Life Insurance Company and Paragon Life Insurance Company of Indiana (collectively the Company ) are strongly committed to preventing the use of its operations for money laundering or any activity which facilitates money laundering, or the funding of terrorist or criminal activities. Accordingly, this policy is developed in compliance with the USA PATRIOT Act of The Company will comply with all applicable laws and regulations designed to combat money laundering activity and terrorist financing, and will cooperate with the appropriate authorities in efforts to prevent any such misuse of Company products or assets. Every employee and independent agent is required to act in furtherance of this policy statement the ( Company AML Policy ) to protect the Company from exploitation by money launderers or terrorists. In furtherance of this Policy, the Company identifies here an AML Compliance Committee, consisting of the Company s chief compliance officer, general counsel, and certain compliance, finance, and accounting officers (to be specified). The Company s AML Policy is intended to supplement, but does not replace, the Anti-Money Laundering Policy promulgated by Guggenheim Capital, LLC on December 9, A link to the Guggenheim Capital AML Policy is provided here. As directed by this policy, the Company will: Take reasonable steps to determine the true identity of all customers; Not knowingly accept funds from or conduct business with customers whose money the Company believes is derived from criminal activity or is intended to conduct, finance or support terrorist activities; Not ignore indications that a customer s money originated from criminal or other money laundering activities or is intended to conduct, finance or support terrorist activities; Take appropriate measures, consistent with the law, when the Company becomes aware of facts which lead to a reasonable suspicion of customer activity; Cooperate fully with law enforcement and regulatory agencies to the extent that it can do so under all applicable foreign and domestic laws; AML POLICY 07/ PHONE FACSIMILE PAGE 4 OF 18

5 Report all identified instances of suspicious activity to the extent that it can do so under all applicable laws; and Comply with all anti-money laundering and anti-terrorism laws and regulations. SCOPE All Company employees, officers and independent agents are subject to this policy and: Are required to read the AML Policy; Are required to attend regular AML training programs if their position is designated by this policy as requiring such; Should avoid drawing conclusions about customers and their activities based solely on the customer s religious affiliation, ethnicity or national origin; and All employees are prohibited from informing independent agents or customers that their activities have been, may be or will be reported as suspicious or under investigation. COVERED PRODUCTS The Company s policy is aimed specifically at covered products. In this context, the Company s covered products are defined as the following types of annuity contracts: individual annuities fixed or variable; and immediate or deferred. STATUTORY PROHIBITION AGAINST DISCLOSURE There are statutory and regulatory prohibitions against the disclosure of information filed in, or the fact of filing, a Suspicious Activity Report ( SAR ) whether the report is required or is filed voluntarily. Thus, the Company, its employees and independent agents are specifically prohibited from disclosing that a SAR has been filed (or that the Company has received a copy of filed joint SAR from another financial institution involved in the same transaction) or the information contained therein, except to appropriate law enforcement and regulatory agencies. If the Company is served with any subpoena requiring disclosure of the fact that a SAR has been filed, or of a copy of the SAR itself, except to the extent that the subpoena is submitted by an appropriate law enforcement or supervisory agency, the Company should neither confirm nor deny the existence of the SAR. The Company also should immediately notify the Office of Chief Counsel at the Financial Crimes Enforcement Network (202) Any Company employee who violates any applicable AML law or regulation, whether through intentional non-compliance, willful blindness or negligence, is subject to disciplinary action, such as probation, remedial training, adverse impact on promotions or compensation reviews, or termination. Also, if any Company employee intentionally violates any applicable AML law or regulation, this will be reported to regulatory and law enforcement officials in accordance with local laws and regulations. DESIGNATION OF ANTI-MONEY LAUNDERING COMPLIANCE OFFICER AND AML COMPLIANCE COMMITTEE The persons listed on APPENDIX A are the designated AML Compliance Officers ( AMLCO ) with overall responsibility for the Company s Anti-Money Laundering Program ( AML Program ). AML POLICY 07/ PHONE FACSIMILE PAGE 5 OF 18

6 They are responsible for, among other things: Being thoroughly familiar with The operations of the business itself; All aspects of the Company anti-money laundering program; The requirements of the Bank Secrecy Act; Applicable Financial Crimes Enforcement Network forms and Having read carefully all applicable documents issued or posted on the web page of the Financial Crimes Enforcement Network of the United States Department of the Treasury: Developing a Risk-Based Program; Monitoring of the Company s compliance with applicable anti-money laundering laws and regulations and with the AML Program; Being available to answer all questions posed by employees; Updating the AML Program as and when necessary; Providing AML training and periodic retraining for employees, independent agents, brokers, and any others doing business with covered products; Designing AML training programs so that these parties have the knowledge necessary to comply with the AML Program; and Reviewing all reports, known as Guggenheim Form - Suspicious Activity Report Internal ( SARI ), from employees and independent agents of suspicious activity and taking suitable action with respect to such SARI reports. Any questions regarding this policy or any suspicious questions or actions by customers should be brought promptly to the attention of the AMLCO. AML COMPLIANCE COMMITTEE APPENDIX B lists the designated members of the AML Compliance Committee. TRAINING Know Your Customer ( KYC ) / Customer Identification Program ( CIP ) - Overview Following Know Your Customer and Customer Identification Program ( CIP ) policies and procedures decreases the chance that you or the Company will be used to facilitate money-laundering activities. In fact, knowing your customer is the single most important deterrent to money laundering. It is unacceptable behavior to knowingly accept funds from or conduct business with customers whose money the Company believes is derived from criminal activity or is intended to conduct, finance or support terrorist activities. Customer Profile The vast majority of customers are not involved in money laundering, so it is important that you be able to identify routine transactions versus suspicious transactions. Performing a needs analysis for a customer not only helps you meet the Know Your Customer requirements but also benefits our business. AML POLICY 07/ PHONE FACSIMILE PAGE 6 OF 18

7 A complete profile for each customer provides you and the Company the ability to: Verify the identity of the customer; Have independent agents visually inspect and make copies of customer driver s licenses or other customer identification documents to verify the applicant s identity; Collect identifying information about the customer, including: Full legal name; Residential address (no P.O. boxes); Social Security Number ( SSN ) or Tax Identification Number ( TIN ); Date of birth; Ensure the financial information that you need to gather for KYC purposes is information you would normally collect in a needs analysis; Identify appropriate transactions and those that may need heightened scrutiny; Detect a pattern of activities that is inconsistent with a customer's stated goals and business; Detect inconsistent patterns of transactions; Anticipate activities that may or may not be related to money laundering and may require further investigation. Enhanced Due Diligence A customer's location, affiliation or type of business may raise red flags (see additional red flags in Exhibit A) that indicate a need for increased scrutiny. For example, regulators have identified Senior Foreign Political Officials as individuals that require greater due diligence. This enhanced due diligence will be conducted by the Company. If an employee becomes aware that a third party requires enhanced due diligence per this section, the employee must escalate the high-risk third party to the appropriate senior manager and the AMLCO for approval. Enhanced due diligence might include more in-depth identification of owners and principals and searches of available litigation, public records, and/or press or media coverage. The AMLCO must obtain approval from the senior business unit manager and consult with Guggenheim Capital s Chief Legal Officer prior to approving 1 a business relationship with a high-risk third party listed below. A Foreign Shell Bank Individuals or organizations identified from a screening review (e.g., Thomson Reuter s World-Check) and confirmed as high risk by an AMLCO 2 1 The Chief Legal Officer may, at his discretion, identify a high-risk third party or a type or group of third-parties that does not require consultation to establish a business relationship. The Chief Legal Officer may, at his discretion, recommend that the approval to establish a business relationship with a high-risk third party be escalated to other senior managers in the business unit or entity, or to a governance committee of the Firm. 2 The AMLCO will provide a report on positive matches to Guggenheim Capital s Chief Legal Officer on a quarterly basis. AML POLICY 07/ PHONE FACSIMILE PAGE 7 OF 18

8 Foreign corporations and individuals that are residents of or nationals of High Risk Jurisdictions Link to List of High Risk Jurisdictions Individuals and entities, domestic or foreign, subject to Legal and Regulatory Actions Additional high-risk third parties include: (i) privately held armament manufacturers, dealers and intermediaries (if known to the Company); (ii) privately held paper currency intensive businesses (e.g., money transfer agents, money brokers, casinos, check cashers, pawnbrokers); and (iii) privately held dealers in precious metals or jewels. Record Retention Federal rules require that all records mandated under the AML regulations: Be kept for five years; and In a reasonably accessible place and manner. In addition, all documents related to the opening of accounts and verification of identity as part of a Critical Infrastructure Protection ( CIP ) must be retained for five years after the account is closed and the termination of any policy or contractual agreement with the customer. If a particular state insurance regulation requires certain documentation to be retained for a longer period, the records must be maintained for the longer time period. Make sure you file any customer identification information you obtain in the customer file along with any information you have provided to the AMLCO. By documenting your actions, you protect yourself from possible penalties. As an independent agent, your responsibility does not end after the initial sale is made. If any of your future interactions with the client seem suspicious, notify the AMLCO. Periodic Reassessment The Company will establish procedures to periodically review its population of third parties in order to assess if any changes have occurred that would warrant enhanced due diligence or escalation of approval (i.e., a high risk party). The frequency and extent of this assessment should be risk-based and may involve obtaining or updating documentation. Training EMPLOYEE TRAINING All employees of the Company will be provided a copy of this policy and will be required to read the policy. In addition to mandatory periodic review of this policy, training will be provided to those employees whose job responsibilities include: Direct customer contact; Access to view and/or execute customer transactions; Processing payments to or from clients or vendors; Supervisory authority over any employee whose responsibilities are referenced in this section. This training will take place at the time of implementation of this policy and at least once annually thereafter. All new hires will be provided a copy of this policy as a part of new employee orientation. New hires requiring training will be provided such as a part of new employee orientation. Documentation of employee training will be maintained by the HR department of the AML POLICY 07/ PHONE FACSIMILE PAGE 8 OF 18

9 Company. The AML Training Program will consist of a review of these Procedures and any additional programs and materials as the AMLCO officers deem necessary or appropriate from time to time. INDEPENDENT AGENT TRAINING All independent agents who are actively producing business for the Company will be required to complete the Company s training program at the implementation of this policy or at the time of their initial appointment, if later. This program will consist of paper or web-based training requiring the independent agent to read the AML Policy and complete a series of questions to confirm the independent agent s knowledge of the program. The Company s administrative system will maintain a record of the independent agent s compliance with this training program. If the independent agent is in default, no contract provided through this independent agent will be processed until the independent agent fulfills the training requirement under this policy. The Company has determined that all agents will be required to complete training through our appointed training vendor, LIMRA or through a training program or provider which is reasonably acceptable to the Company. Independent Audit There will be a periodic independent audit to test and evaluate compliance with and the effectiveness of the Company s AML Program. The internal audit department of the Company will perform this audit annually. Monitoring and Reporting SUSPICIOUS ACTIVITIES Employees and independent agents are responsible for identifying the expected activities of your customers in order to establish a range of typical actions. Any fact or circumstance that falls outside this range of typical actions is termed a red flag by FinCEN and should be considered suspicious or unusual, especially where the economic gain is not obvious or clear. If you suspect or know that a transaction involves funds related to an illegal activity or is designed to avoid regulations, you must report the transaction to the Company's AMLCO by completing Guggenheim Form Suspicious Activity Report Internal (EXHIBIT B). Through performance of their daily activities, all employees and independent agents shall monitor customer activity. Although no single activity or factor is necessarily indicative of suspicious activity, all such instances of a single activity or factor that could be indicative, but not necessarily indicative of suspicious activity, should be reported to the AMLCO. The AMLCO will evaluate such single, potentially suspicious activities together with other factors, such as length of time the Company has known the customer. All employees and independent agents of the company should frequently review and become familiar with attached EXHIBIT A, Suspicious Activity Guidance, that provides an extensive list of red flag events indicating suspicious activity. (NOTE: This list should not be considered comprehensive or all-inclusive. Each independent agent or employee must understand the intent of the law so that any suspicious activity whether listed specifically herein or not is detected and reported to the AMLCO.) AML POLICY 07/ PHONE FACSIMILE PAGE 9 OF 18

10 Procedures SUSPICIOUS ACTIVITY REVIEW If you identify a suspicious activity, you must not notify the customer. Employees and independent agents are prohibited from Informing customers that their activities have been or may be reported as suspicious, That a Suspicious Activity Report Insurance Company is filed, or That an ongoing investigation regarding activities in his or her account is being conducted. In the event that any employee or independent agent becomes aware of any activity listed in EXHIBIT A - Suspicious Activity Guidance Red Flags attached to this policy, then that individual is required to immediately complete the EXHIBIT B - Company Form - Suspicious Activity Report - Internal ( SARI ) and submit it to their supervisor and the AMLCO for review. The AMLCO will notify senior business unit management and Guggenheim Capital s Chief Legal Officer. 3 In the event that any employee or independent agent becomes aware of any activity not listed in EXHIBIT A, but that the individual feels may qualify as suspicious activity under this policy, then that employee or independent agent is required to immediately complete the SARI and submit it to the AMLCO for review. Any employee or independent agent receiving an inquiry regarding the AML Policy should immediately document this inquiry on a SARI and submit it to the AMLCO. RECEIPTS LOG The New Business Department will maintain a log of all receipts of Certified or Cashier s checks Any other unusual method of payment and Federal wire transfers. COMPANY FORM: SUSPICIOUS ACTIVITY REPORT - INTERNAL ( SARI ) AND FINCEN FORM: SUSPICIOUS ACTIVITY REPORT ( SAR ) AMLCO will perform the following procedures: Review and investigate all SARI submissions; No later than 30 days following the discovery of any known or suspected activity, take proper action either to dismiss each SARI, or to complete and file with FinCEN a FinCEN Form Suspicious Activity Report (EXHIBIT B); and Review cashier log quarterly for presence of any pattern or suspicious activity; and, Provide initial AML training and periodic retraining for 3 The Chief Legal Officer may, at his discretion notify other senior managers, including those in the relevant business unit or entity, or to a governance committee of Guggenheim Capital. AML POLICY 07/ PHONE FACSIMILE PAGE 10 OF 18

11 Employees, Independent agents, Brokers, and Any others doing business with covered products WORLD-CHECK COMPLIANCE Testing The Company must determine, within a reasonable period after an account is opened or a policy is purchased, whether the applicant s name appears on a list of known or suspected money launderers, terrorist organizations, and other criminals maintained by the Treasury Department s Office of Foreign Assets Control ( OFAC ), called the Specially Designated Nationals and Blocked Persons list. Before issuing an insurance policy or annuity, and on a periodic basis, the AML Compliance Officer will check to ensure that the names of any contract owners, annuitants and beneficiaries do not appear on the OFAC Specially Designated Nationals and Blocked Persons List ( SDN List ) and that such persons are not known to reside in, do business in, or engage in transactions with people or entities from, embargoed countries and regions listed on the World-Check Web Site. The AML Compliance Officer will run the same check on any person due to receive any distribution or benefit payment from an insurance policy or annuity (including any policy loan, withdrawal, surrender, annuity payment or payment of a death benefit) before such distribution or benefit payment is made. No Matches: The AML Compliance Officer will retain copies of all search results of names against updated World-Check lists. False Positives or Possible Matches: In the event that a search result yields a hit or exception, the AML Compliance Officer will request additional identifying information from the affected person. The AML Compliance Officer will review the additional documentation to determine whether the hit is a false positive or a possible World-Check match. If the hit or exception is a false positive, the AML Compliance Officer will sign, date and make a notation on the exception report that the hit is a false positive, not a match, and will file the supporting documentation with the exception. If the identifying information provided by the affected person is insufficient to resolve the hit or exception, the AML Compliance Officer will make a determination whether to conduct enhanced due diligence in an effort to resolve the exception.. The AML Compliance Officer will file and retain the exception report, resolution (e.g., false positive), and the copies of the supporting documentation. The AML Compliance Officer will provide a report on positive matches to Guggenheim Capital s Chief Legal Officer on a quarterly basis. Notice to Customer Form As part of the Company s CIP program, a Notice to Customer must be given to every applicant for a covered product (EXHIBIT C). The purpose of a Notice to Customer is to disclose the Company s intent to verify the customer s name and personal information. The degree of verification effort required will be determined by the extent of the risk, such as the amount of premium deposit or unusual circumstances involving the transaction. Applicants who refuse to provide personal information will be declined. Company is prohibited from: Accepting cash (coin or currency), money orders or travelers checks for any transaction; Accepting negotiable checks drawn on independent agent accounts; AML POLICY 07/ PHONE FACSIMILE PAGE 11 OF 18

12 Accepting foreign checks; Accepting personal checks drawn on anyone other than the contract owner with the exception of checks drawn on the account of legal guardian of a minor, parent or grandparent of a minor; Civil and Criminal Penalties The penalties associated with money laundering are severe. Fines may be twice the amount of the transaction up to $1 million. Property involved in the transaction may also be subject to seizure and forfeiture. Employees of financial institutions can be fined individually and sentenced to up to 20 years of imprisonment for knowing or being willfully blind to the fact that the transaction involved illegal funds. You can protect yourself from charges of willful blindness by reporting any suspicious behavior to the AMLCO and keeping documentation of your report. Updates, Modifications and Exceptions The Company shall update the AML Program as necessary to maintain its effectiveness. Updates to the AML Program shall be undertaken based on the recommendations of the AML Compliance Officers, the results of testing and any changes in the Company s legal duties. The AML Compliance Officers may make such modifications and exceptions to the policies and procedures implementing the AML Program as the AML Compliance Officers deem reasonable and appropriate, provided that such modifications or exceptions are consistent with the Company s policy to maintain reasonable and effective policies and procedures to detect and deter money laundering, terrorist financing and transactions prohibited under any applicable anti-money laundering laws. Any such modifications or exceptions shall be documented in writing by the AML Compliance Officers. Information Sharing with Law Enforcement and Supervisory Authorities NOTE The following policies and procedures apply to all transactions involving the Company, not just those involving Covered Products. GENERAL A federal law enforcement agency or other law enforcement or supervisory authority investigating terrorist activity or money laundering may request information from the Company to facilitate an investigation. The Company shall cooperate with lawful requests for information from such authorities. DESIGNATED CONTACT PERSON The AML Compliance Officers are the point of contact for the Company for investigative issues or similar requests for information from law enforcement or supervisory authorities. All such requests shall be referred to the AML Compliance Officers. AML POLICY 07/ PHONE FACSIMILE PAGE 12 OF 18

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