POCA puzzlers for insurers

What does the Proceeds of Crime Act 2002 (POCA) mean for commercial insurers, their brokers and clients? Long-term life business might be caught by the ambit of Schedule 9 of POCA and the Money Laundering Regulations 2003 as a potential stop-off point for dirty funds - the usual example is early redemption of annuities, with scant regard for penalty – but surely the commercial insurance sector does not need to worry? Unhappily, the more that CMS Cameron McKenna’s insurance and reinsurance lawyers looked the more convinced they became that their clients face all too real legal risk exposure. They took their concerns to Tom Weitzman QC of 3 Verulam Buildings, Gray’s Inn and spent a tough few hours working through some real-life scenarios.Their deliberations led to an instructive seminar when a selection of case studies were explored. Mr Weitzman began by picking through the offences in Part VII of POCA.