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9/10          W01/March 2017  Award in General Insurance




                        Using 1998 statistics, these percentages indicate that money laundering ranged between US$590 billion
                        and US$1.5 trillion. However, it must be said that overall it is absolutely impossible to produce a reliable
                        estimate of the amount of money laundered.
                        The integrity of the banking and financial services marketplace depends heavily on the perception that it
                        functions within a framework of high legal, professional and ethical standards. A reputation for integrity
                        is the one of the most valuable assets of a financial institution.
                        If funds from criminal activity can be easily processed through a particular institution – either because
                        its employees or directors have been bribed or because the institution turns a blind eye to the criminal
                        nature of such funds – the institution could be drawn into active complicity with criminals and become
                        part of the criminal network itself. Evidence of such complicity will have a damaging effect on the
                        attitudes of other financial institutions and of regulatory authorities, as well as customers.
                        On the same note, a financial institution that carries out a transaction, knowing that the funds or
                        property involved are owned or controlled by terrorist organisations, or that the transaction is linked to
                        terrorist activity, may be committing a criminal offence under the laws of many jurisdictions. Such an
                        offence may exist regardless of whether the assets involved in the transaction were the proceeds of
                        criminal activity or were derived from lawful activity but intended for use in support of terrorism.
                        Regardless of whether the funds in a transaction are related to terrorists for the purposes of national
                        criminal legislation, business relationships with such individuals could expose a financial institution to
                        significant reputational, operational, and legal risk. This risk is even more serious if the person or entity
                        involved is later shown to have benefited from the lack of effective monitoring or wilful blindness of a
                        particular institution and was to carry out terrorist acts.

                        As for the potential negative economic consequences of unchecked money laundering, this can include
                        changes in money demand, prudential risks to bank soundness, contamination effects on legal financial
                        transactions, and increased volatility of international capital flows and exchange rates due to
                        unanticipated cross-border asset transfers. Also, as it rewards corruption and crime, successful money
                        laundering damages the integrity of the entire society and undermines democracy and the rule of
                        the law.
                        The possible social and political costs of money laundering, if left unchecked or dealt with ineffectively,  Reference copy for CII Face to Face Training
                        are serious. Organised crime can infiltrate financial institutions, acquire control of large sectors of the
                        economy through investment, or offer bribes to public officials and indeed governments.

                        The economic and political influence of criminal organisations can weaken the social fabric, collective
                        ethical standards and ultimately the democratic institutions of society. In countries transitioning to
                        democratic systems, this criminal influence can undermine the transition. Most fundamentally, money
                        laundering is inextricably linked to the underlying criminal activity that generated it. Laundering enables
                        criminal activity to continue.
                         Question 9.3

                         Briefly outline the three stages of money laundering.

                        D1A Vulnerabilities in insurance

                        Life assurance and general insurance can be used in different ways by money launderers and terrorist
                        financiers. The vulnerability depends on factors such as the complexity and terms of the contract,
                        distribution, method of payment (cash or bank transfer) and contract law. Insurers should take these
    9                   factors into account when preparing a risk profile of the type of business in general and of each business
    Chapter             relationship.

                        Examples of the type of life insurance contracts that are vulnerable are products such as:
                        • unit-linked or with profit single premium contracts;
                        • single premium life insurance policies that have cash value;
                        • fixed and variable annuities; and
                        • (second hand) endowment policies.
                        When a life insurance policy matures or is surrendered, funds become available to the policyholder or
         Funds become
         available to the  other beneficiaries. The beneficiary to the contract may be changed before maturity or surrender, so that
         policyholder or other  payments are made by the insurance company to a new beneficiary. A policy might be used as collateral
         beneficiaries
                        to purchase other financial instruments. These investments may be one part of a sophisticated web of
                        complex transactions with their origins elsewhere in the financial system.
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