Sector assessment
10 laundering methods apply to this sector. 7 are rarely covered in standard AML training. The sector assessment uses 10 cases.
Insurance proceeds receive less downstream scrutiny because they arrive from a regulated insurer, which makes the payout itself a laundering mechanism.
Financial crime controls concentrate at claims, because claims are where fraud against the insurer happens. Laundering runs the other way: the premium is genuine, the claim may never come, and the firm loses nothing. Nobody is incentivised to investigate a customer who overpays and then walks away.
Life insurance is a regulated sector under the Money Laundering Regulations, and FATF maintains dedicated risk-based approach guidance for it, issued October 2018. FATF's own typology work records that payments originating from insurers are widely assumed to be clean and attract little downstream scrutiny — the assumption the typology depends on.
This is written for life and investment-related insurance, and for the intermediaries who place it. General insurance sits outside the Money Laundering Regulations, so a motor, property or commercial lines broker is not a relevant person and this assessment is not aimed at you. The line runs through the product rather than the firm: a composite insurer or a broker doing both is in scope for the life and investment side of the book only.
Not one case. Every case that exercises a typology on your list is part of your mark, weighted by how much of your exposure it carries. The weights are derived from the register rather than chosen, so adding a case re-derives them instead of leaving the old ones wrong.
| Case | Your typologies | Share of your mark |
|---|---|---|
| The Policy Bookwritten for your desk | 7 | 28% |
| The Verification Desk | 5 | 23% |
| The Relationship Review | 3 | 14% |
| The Betting Account | 1 | 5% |
| The Client Account | 1 | 5% |
| The Exchange Desk | 1 | 5% |
| The Incoming Payment | 1 | 5% |
| The Onboarding Interview | 1 | 5% |
| The Securities Book | 1 | 5% |
| The Sponsorship File | 1 | 5% |
£99one payment, 12 months, nothing renews
£750pilot, up to 25 people, invoiced
Drawn from the full register and filtered to this sector. Each entry states what the typology looks like inside your own systems, and names the source it came from. 10 of the 10 are currently exercised by an assessment case; the rest are documented here and not yet built into one.
Deceased individuals are recorded as directors, officers and shareholders, and accounts opened by the living are run on after death. There is no accomplice who can be pressured, because the nominal principal is dead.
An account in good standing whose signatory died in a jurisdiction the firm does not search, filings continuing for a director with no verifiable life, and mandates never refreshed because the account never triggered a review.
Layered holding structures across free-zone and offshore jurisdictions terminate in a corporate nominee, so the declared beneficial owner is asserted rather than evidenced.
A structure chart that never evidences control, a nominee shareholder defeating verification, and a customer who offers further documents instead of an answer.
Statements, identity documents and supporting evidence are generated rather than obtained, and are internally consistent in ways genuine documents are not.
Statements with no fees or charges across months, running balances consistent to the penny, logos at incorrect aspect ratio, institution codes in the wrong format, identity photographs internally inconsistent or inconsistent with stated age, third-party webcam plugins during liveness checks.
A person who does not exist is assembled from a mixture of real and fabricated data, passed through onboarding, allowed to build a credit and transaction history, and then used as durable laundering infrastructure rather than for a single fraud.
Thin-file customers who behave impeccably for months, clusters sharing partial attributes such as address, device or contact details, credit files that begin abruptly in adulthood, and accounts whose only real purpose emerges long after onboarding.
Cloned voice defeats the control the firm added to catch impersonation: the callback. Voice biometrics and telephone banking authentication are attacked with audio generated from publicly available recordings.
Voice authentication passing on a call whose channel or device signals are inconsistent with the customer, callbacks answered on newly registered numbers, and instructions confirmed by voice that the customer later disputes entirely.
Synthetic video and voice impersonate executives on a live call to authorise urgent transfers, defeating the callback and video-verification controls firms adopted precisely to stop email-based impersonation.
Multiple urgent same-day transfers to new beneficiaries authorised by one employee, outside normal approval patterns, following a confidential instruction the payer cannot corroborate internally.
A policy is used as a store and cleaning mechanism: a large single premium is paid, the policy is surrendered early at a deliberate loss, and the proceeds leave as an insurer payment, which downstream institutions treat as inherently clean.
Single premium payments from third parties or unrelated jurisdictions, early surrender accepted at a material penalty, frequent changes of beneficiary, and cooling-off cancellations with refunds directed to a different account from the one that paid.
Capability is rented rather than built. Subscription platforms supply mule account provisioning, KYC-bypass tooling, synthetic identity generation, deepfake kits and end-to-end laundering, so an operator needs money rather than skill.
The same tooling signature across customers with no other connection: identical document templates, shared device or capture characteristics, and mule accounts appearing in coordinated batches rather than individually.
Improper payments are routed as consultancy fees, royalties, dividends or capital gains so the receipt reads as ordinary income.
Consultancy receipts from jurisdictions where the recipient holds influence, payments unconnected to any deliverable, and timing correlated with contract awards.
Ownership is diluted below control thresholds or transferred to non-designated relatives and managers after designation, leaving effective control unchanged.
Ownership changes closely following a designation date, incoming owners with no commercial history, and unchanged management across the restructuring.
The Policy Book carries 7 of the 10 typologies above and 28 per cent of your mark. Full debrief, no account, no card.
Start The Policy BookRun the full Insurance benchmark across up to 25 people for £750.
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One documented case each week. One decision. The answer and the source afterwards.
