As complex market forces force smaller and independent firms selling Life Settlements to investors out of business, the giants in the industry gobble up the inventories of their former competitors. Inasmuch as there are no regulations requiring that Life Settlement companies maintain an effective AML/CFT program, the odds that enterprising money launderers were in the past able to embed their criminal clients into a significant number of investments at the now-defunct little companies, is significant.
When those investments are sold by failing Life Settlement firms to the bigger players in the industry, there is no compliance done on the existing investors, and when the investments mature ( the insured on those large policies pass away), and the insurance carrier which issued the policies pay off what can be millions of dollars, the Proceeds of Crime are artfully cleaned and laundered.
I bring this up, as most compliance officers accept eight-figure payments from the world's largest life insurance companies without any further inquiry, believing, in error, that sufficient due diligence was previously completed, when in truth and in fact, only the original beneficiary was vetted, not the successor, which was precisely where the money launderer was able to work his magic, in the secondary market for life insurance that is the Life Settlement industry.
If you do not have a thorough understanding of Money Laundering through Life Settlements, you might want to seriously consider attending my upcoming January 20th virtual seminar on advanced, esoteric and obscure money laundering techniques. You can obtain details here:
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