As much as the banking industry, perhaps even more, insurance is a sector highly vulnerable to money laundering. Given the maxim that insurance products are 'sold, not bought', it has an aggressive sales culture driven by agents, working on a commission basis; this often conflicts with any rules or norms that require asking too many probing questions of the customer and their source of funds. And finally, insurance products can be quite complex, which translates into multiple ways and means to exploit loopholes in norms.

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