Insurance and Reinsurance Manipulation

Insurance and Reinsurance Manipulation: Criminals manipulate the complexity of insurance and reinsurance markets, including captive or offshore insurance entities, to conceal illicit proceeds. Common methods include inflating premiums, fabricating or exaggerating claims, and structuring multilayered cross-border reinsurance deals. In some cases, criminals even create fraudulent insurance or reinsurance companies to further legitimize illicit proceeds behind a veneer of normal activity. By repeatedly shuffling funds through these products and arrangements, they obscure the true origin of the money before ultimately presenting payouts or settlements as legitimate income.

[
Code
T0090
]
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Name
Insurance and Reinsurance Manipulation
]
[
Version
1.0
]
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Parent Technique
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Tactics
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[
Risk
Product Risk, Jurisdictional Risk
]
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Created
2025-02-27
]
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Modified
2025-04-02
]

Tactics

ML.TA0007
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Criminals exploit cross-border reinsurance contracts, inflated premiums, and fabricated claims to create multiple layers of transactions, making it significantly more difficult to trace the original criminal source.

Risks

RS0002
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Product Risk
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This technique primarily exploits the inherent features of insurance and reinsurance products, allowing criminals to inflate premiums, fabricate or exaggerate claims, and shuffle funds through multiple contractual layers. These open-ended or flexible product structures obscure illicit proceeds among normal policy transactions before they resurface as seemingly legitimate payouts or settlements.

RS0004
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Jurisdictional Risk
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Criminals leverage offshore or multinational reinsurance agreements involving regions with weaker AML controls and secrecy laws. By routing funds through jurisdictions that lack robust regulatory oversight, they increase opacity and further complicate financial institutions’ efforts to trace the ultimate source of the illicit proceeds. This operates as a secondary, distinct risk layer supporting the primary product-based manipulation.

Indicators

IND00953
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Frequent cross-border reinsurance transactions involving jurisdictions known for secrecy or weak regulatory oversight.

IND00954
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Significant discrepancies between the premium amounts paid and the actual risk covered by the policy.

IND00955
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Captive insurance firms established in tax havens with inflated premium payments or excessive claims relative to industry norms.

IND01697
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Frequent and high-value premium payments to reinsurance companies located in secrecy jurisdictions.

IND01698
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Complex reinsurance structures involving multiple layers of reinsurance across various countries with limited transparency.

IND01699
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Unusually high number of claims filed with captive insurance companies that are disproportionate to the insured risk.

IND01700
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Captive insurance companies established in jurisdictions known for weak regulatory oversight.

IND01701
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Premiums significantly inflated compared to typical market rates for similar coverage.

IND01702
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Policies issued by offshore insurers that are canceled soon after issuance with refunds or payouts.

IND01703
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Reinsurance agreements with terms that are not standard in the industry or that lack economic justification.

IND01704
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Involvement of entities with opaque ownership structures in reinsurance agreements.

IND01705
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Reinsurance transactions involving entities with no prior history in the insurance sector.

IND01706
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Early cancellation of insurance policies with substantial payouts that do not align with typical industry practices.

IND01707
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Reinsurance agreements involving shell companies or entities with minimal operational history.

IND01708
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Use of unregulated or lightly regulated offshore insurers to issue policies that are subsequently canceled for large payouts.

IND01709
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Patterns of reinsurance claims featuring unusually rapid processing and settlement in amounts inconsistent with normal claim lifecycles.

IND01710
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Reinsurance agreements structured in a complex manner that obscures the true ownership of entities involved.

IND01711
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Involvement of individuals or entities previously flagged for financial crimes in the management or ownership of captive insurance firms.

IND01712
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Repeated partial surrenders or refunds from overfunded insurance policies that incur significant penalties without plausible business justification.

Data Sources

  • Identifies offshore or secrecy jurisdictions with lax regulations frequently involved in manipulated insurance schemes.
  • Flags high-risk regions or countries for suspicious cross-border premium or claim transfers.
  • Shows how insurance policies are utilized, including the frequency of claims, early cancellations, or unusual usage patterns.
  • Reveals abnormal usage such as short policy durations, large refunds, or partial surrenders, indicating potential manipulation.
  • Contains reinsurance contracts, invoices, and billing details that may reveal unusual terms.
  • Detects inflated premiums, fabricated claims, or other anomalies in contract structures.
  • Provides detailed records of premium payments, claim payouts, refunds, and other insurance-related transactions to identify suspicious or inflated amounts.
  • Enables detection of layering schemes through frequent or structured cross-border payments.
  • Reveals patterns of early cancellations, large refunds, or partial surrenders inconsistent with typical insurance practices.
  • Aggregates background information on all involved parties, confirming legitimacy or highlighting red flags.
  • Verifies whether entities have an operational history in insurance or connections to prior financial crimes.
  • Reveals an entity’s actual operational scope, risk exposure, and typical insurance needs.
  • Identifies mismatches between legitimate business activity and the scale of insurance premiums or claims, suggesting manipulation.
  • Provides independent audit findings on financial statements, highlighting inflated premiums, irregular claims, or non-standard reinsurance practices.
  • Offers insight into discrepancies between reported figures and actual insurance activity.
DS0033
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  • Contains known fraud or financial crime records for individuals or entities.
  • Helps identify high-risk parties engaged in questionable insurance or reinsurance schemes.
  • Allows comparison of typical market rates for insurance or reinsurance arrangements.
  • Helps detect significantly inflated premiums or coverage that deviate from standard industry benchmarks.
  • Tracks cross-border reinsurance payments to detect unusually large or frequent transactions.
  • Highlights offshore reinsurance flows potentially aimed at hiding illicit proceeds or layering schemes.
  • Provides official registration and beneficial ownership details of insurers, reinsurance entities, or associated shell companies.
  • Uncovers opaque or layered ownership structures used to conceal the ultimate owners behind manipulated insurance arrangements.

Mitigations

Conduct in-depth reviews of captive insurance or reinsurance clients, verifying beneficial ownership structures, premium financing arrangements, and claim payment histories. Institutions must confirm the insurer’s domicile, licensing status, and any prior regulatory flags. By focusing on potentially inflated premiums and suspicious claim reimbursements, EDD directly addresses the layering vulnerabilities inherent in complex insurance transactions.

Implement tailored rules and analytics to detect unusual insurance premium flows, repeated partial surrenders, or high-value claim payouts inconsistent with policy terms. Pay special attention to early cancellations with large refunds, cross-border fund movements lacking clear economic rationale, and multi-layer reinsurance deals with questionable risk coverage. Promptly investigate alerts to uncover potential insurance manipulation.

Require comprehensive vetting of brokers, underwriters, reinsurers, and captive insurance managers, particularly those in offshore or loosely regulated jurisdictions. Assess corporate governance, past regulatory sanctions, and AML compliance rigor. Mandate periodic reviews of service contracts to ensure that third parties do not facilitate opaque layering or inflated premiums.

Provide specialized training for underwriting, claims, and compliance teams to recognize red flags unique to insurance manipulation, including suspect premium overfunding, exaggerated claims, or repeated early policy cancellations. Emphasize multi-layer reinsurance schemes, offshore captive structures, and unusual claim settlement patterns to enable timely identification and escalation.

Assign higher-risk ratings to entities engaged in captive or offshore reinsurance arrangements, multi-layered reinsurance deals, or frequent policy cancellations lacking valid justification. Calibrate transaction monitoring scenarios, alert thresholds, and manual reviews according to the increased risk. By tailoring scrutiny to these high-risk profiles, institutions can better target potential insurance/reinsurance manipulation.

Conduct targeted audits of insurance underwriting, reinsurance contracts, and claim settlement processes to identify overlooked anomalies or potential control failures. Examinations should focus on policy cancellations, excessive premium fluctuations, and opaque captive structures. Timely audits reinforce the effectiveness of AML controls and reveal manipulation buried within complex insurance deals.

Leverage external insurance databases, corporate registries, and open-source intelligence to confirm the legitimacy, licensing, and operating history of insurers and reinsurers. Validate the plausibility of stated premium levels and claim activities by cross-checking with public records, industry benchmarks, and negative news sources. This ensures that shell or unlicensed insurance entities are quickly identified and mitigated.

Maintain continuous oversight of policyholders and reinsurance partners by updating risk profiles, reviewing transactional behavior, and revalidating beneficial ownership details. Track premium payments and claim activity over time to detect traditional layering indicators, such as inflated policy values, abrupt cancellations, or disproportionate claim volumes. These recurring checks help expose evolving fraud schemes within insurance programs.

Instruments

  • Criminals deliberately overfund single-premium or investment-linked policies with illicit cash, disguising these contributions as normal premium payments.
  • They then request early withdrawals or surrenders, absorbing penalties as a cost of layering, thereby receiving purportedly legitimate payouts.
  • By employing captive or offshore insurers, criminals place these overfunded premiums in jurisdictions with weak transparency, further obscuring the origin of the funds. Upon withdrawal, the funds reemerge as standard policy disbursements or refunds.

Service & Products

• Criminals move manipulated insurance proceeds into decentralized exchange protocols to obscure transaction trails.
• Limited KYC requirements and pseudonymous accounts hinder effective source tracing.
• Rapid cross-border transfers via decentralized platforms add extra layers of complexity, facilitating further layering of laundered funds.

• By creating complex or bogus reinsurance contracts, criminals inflate premiums and fabricate claims to route illicit proceeds through multiple entities.
• Layering is achieved as funds traverse various reinsurers—often offshore—masking the true source of the money.
• Final payouts or settlements ultimately appear as legitimate insurance or reinsurance transactions, enabling integration into the financial system.

• Criminals overfund single-premium or investment-linked policies with illicit money and later request refunds or partial surrenders disguised as normal policy disbursements.
• The regulated appearance of these products helps legitimize the funds, making it harder to identify the criminal origin.
• Flexible premium payments and early withdrawals enable repeated layering and concealment within purportedly standard insurance transactions.

Actors

Criminals exploit or create insurance companies, including fraudulent offshore entities, by:

  • Inflating premiums, faking or overstating claims, and channeling illicit funds as routine policy transactions.
  • Using complex or layered cross-border reinsurance deals that obscure beneficial ownership and payment trails.

Ultimately, payouts from these manipulated policies blend illicit capital with legitimate insurance proceeds, hindering financial institutions' efforts to detect the underlying criminal source.

Captive insurance managers establish or administer captive insurers that criminals use to:

  • Funnel illicit proceeds through premium payments or fabricated claims in arrangements where the same criminal parties control both the insurer and the insured.
  • Leverage offshore or lightly regulated jurisdictions, reducing transparency and complicating financial institutions’ oversight of premium and claim inflows.
  • Form self-contained insurance structures that obscure ownership and mask the true origin of funds under the guise of legitimate coverage.

Illicit operators orchestrate insurance and reinsurance manipulations by:

  • Establishing or controlling fraudulent insurance providers to inflate premiums, fabricate claims, or shuffle funds across multiple reinsurance layers.
  • Obscuring the criminal origin of funds, making payouts appear as legitimate policy settlements.

Their activities impede financial institutions' ability to trace payment flows, as transactions are masked under seemingly normal insurance arrangements.

References

  1. Campbell, A. M. (2021). Money Laundering, Terrorist Financing, and Tax Evasion: The Consequences of International Policy Initiatives on Financial Centres in the Caribbean Region. Palgrave Macmillan. https://doi.org/10.1007/978-3-030-68876-9

  2. Dall, E., Keatinge, T. (2018, July). Underwriting proliferation: Sanctions evasion, proliferation finance and the insurance industry. Royal United Services Institute for Defence and Security Studies. https://www.rusi.org/explore-our-research/publications/occasional-papers/underwriting-proliferation-sanctions-evasion-proliferation-finance-and-insurance-industry

  3. Shanmugam B., Thanasegaran H. (2008). Exploitation of the insurance industry for money laundering: the Malaysian perspective. Journal of Money Laundering Control, Vol. 11 No. 2, pp. 135-145. https://doi.org/10.1108/13685200810867465

  4. Law Officers, Joint Financial Crimes Unit and the Jersey Financial Services Commission. (2008). Anti-Money Laundering/Countering the Financing of Terrorism Typologies from a Jersey perspective. https://www.gfsc.gg/sites/default/files/AML-CFT%20-Typologies-from-a-Jersey-Perspective.pdf