Athene Anti‑Money Laundering Program Update

Because you have important insights into an annuity purchase, like the client’s personal identity, financial objectives and source of funds, you play a critical role in ensuring the security of all parties.

In compliance with state and federal regulations for insurance companies, we’ve adopted a detailed Anti-Money Laundering (AML) Program. As a producer who maintains a direct relationship with the customer, you have an obligation to:

• Protect the Company and your customers against financial crime;
• Be well informed by fulfilling the required financial crime training;
• Be diligent in observing customer interaction for suspicious activity, and
• Report any suspicious activity that may be related to anti-money laundering or any financial crime.

For you to sell an Athene product, you are required to assist in combating financial crime by adhering to all AML guidelines which include:

Customer Identification

All producers are required to meet the “Know Your Customer” requirements as part the program. This means that you must validate the identity of each applicant (and payor) by collecting sufficient personal information to help identify the applicant as well as describing basic financial information and establishing the primary reason for purchasing the product.

Information requested will include name, date of birth, Social Security/Tax Identification Number, citizenship/permanent resident information, physical residential address, and financial/employment information. The financial information and reason for the purchase help validate that the purchase is being made for a legitimate purpose and help support the suitability of the sale.

Completing your Know Your Customer (“KYC”) responsibilities will reduce the chance that you or Athene will be involved in money-laundering activities.

Athene reserves the right to require a copy of the non-expired government issued identification you obtained as the producer. Athene also reserves the right to decline an application or payment if the company cannot obtain sufficient information to establish the identity of any applicant or the source of the payment.

Forms of payment accepted by Athene

• We will only accept funds drawn from a U.S.A. bank.
• Personal checks must have the name and address of the owner preprinted on the front of the check.
• Cashier’s checks must be purchased by the applicant/contract owner and the customer’s name must be noted as the remitter on the cashier’s check. As the producer, you are not allowed under our guidelines to purchase a cashier’s check on behalf of an applicant or contract holder.
• Wire transfers must originate from the owner’s account and must be drawn from a U.S.A. bank.
• We will not accept cash, money orders or other cash equivalents for premiums or additional deposits.
• We will not accept funds from the producer or agency except in cases where the producer is the applicant or when the producer has completed the Producer Submitted Annuity Additional Premium Payment form (20440).

For additional guidance, please refer to the Doing Business with Athene Guide (19608), the Company Rules on Anti-Money Laundering (18545), The Guidelines for Writing Annuity Business on Foreign Individuals (18542), and Forms of Payment (18544) guidelines for additional information.

Record keeping

As the producer, you (and Athene) have record keeping responsibilities. Records must be maintained for 5 years following the termination, cancellation or surrender of an annuity. Information to be retained includes:

• A copy of the non-expired identification used by the customer to open the account, the customer’s name, date of birth, address, and tax identification number.
• A description of any document used to verify customer identity, noting the type of document, a document identification number, the place of issuance, the date of issuance and the document expiration date.
• A description of the methods and results of non-documentary measures used to verify identity (viewing of non-expired government issued identification).
• A description of any substantive discrepancy between the identifying information provided by the customer and that found in identifying methods, noting how the discrepancy was resolved.

Producer training

Federal regulations require all producers to complete Anti-Money Laundering (AML) training. Athene requires all producers to complete training upon appointment and every two years thereafter. You will not be able to write business unless the AML training is completed.

Athene has partnered with the Life Insurance and Market Research Association (LIMRA) to offer the AML training course at no cost to you. The training will take approximately 30 minutes to complete. You do not need to contact Athene after completion, as LIMRA will provide Athene with notification within 48 business hours of your completion of the AML course.

The course may be accessed at https://aml.limra.com. Your Username is the first four letters of your last name combined with the last six digits of your social security number, unless otherwise communicated. If you are a first-time user, your password is your last name (lowercase). If you are a returning user to the LIMRA site, use the password you created the first time you logged in. If you have forgotten your password, click Forgot Your Password and follow the prompts to reset your password online.

Complete the course titled The Importance of Knowing Your Customer – Anti-Money Laundering for Insurance Review. Please note that you will not receive a certificate of your completion of the course. The Home Page indicates whether you have completed the assigned material. If you have questions regarding the LIMRA training site, please contact support@cfmpartners.com or call (866) 364-2380 for assistance.

If you have completed the required AML training through a provider other than LIMRA, you must submit a copy of the certificate to our office via fax to (800) 531-0038 or electronic mail at submitproducerdocs@athene.com for our review.