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伴随全球经济一体化和金融创新的不断发展,保单贴现业务也将在国内迅速发展,但其中暗含的洗钱风险需要对其做前瞻性研究。主要分析保单贴现洗钱的具体方式、行为动机和主要特征,然后提出保单贴现洗钱风险防范的初步建议,包括优化反洗钱的宏观战略和采取针对性的反洗钱措施。其中,对实施“风险为本”的反洗钱策略、拓展对洗钱概念的法律定义、拟定保单贴现洗钱的可疑交易行为指南等举措作了较详细论证。
With the continuous development of global economic integration and financial innovation, policy discount business will also be rapidly developed domestically. However, the implicit risk of money laundering needs to be prospectively studied. The paper mainly analyzes the specific methods, behavioral motivations and main features of the policy of discounted money laundering. Then, it puts forward the preliminary suggestions on how to prevent the risk of discounted money laundering, including the macroeconomic strategy of optimizing the anti-money laundering and the targeted anti-money laundering measures. Among them, a more detailed demonstration is made on such measures as the implementation of the “risk-based” anti-money laundering strategy, the expansion of the legal definition of the concept of money laundering and the development of a guide to suspicious transaction of policy discounted money laundering.