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By Nicolas MARINIER, Partner and Emilie RUBAYIZA, Senior Manager at Deloitte Luxembourg
Due to fewer transactions, some might mistakenly assume that the insurance sector bears a lower money laundering and terrorist financing (ML/TF) risk than banks and investment funds. But the insurance sector is not immune to ML/TF, and this misperception is dangerous:
1. Criminals may target the insurance industry to commit their fraud or transgress Targeted Financial Sanctions (TFS). While TFS violation and fraud are now clearly identified by Luxembourg Penal Code (art. 506-1) as primary ML offenses, “classic” ML/TF risks, like drug trafficking, prostitution, tax crime or corruption should not be forgotten or overlooked.
2. Money launderers aim to...
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