Publication

How New AML Law Will Apply To Life Settlement Industry

Law360
June 23, 2021

Atlanta’s Brian Casey and Tom Sherman co-authored an article on potential implications of the new federal Corporate Transparency Act (CTA) for life settlement, or secondary life insurance market, industry participants. Casey and Sherman outline changes to the definition of a reporting company, an applicant and a beneficial owner, the application of the CTA to the life insurance industry and penalties for violating the CTA. The authors note, “The CTA will provide information about the beneficial ownership of some life settlement investment funds to FinCEN in contrast to state insurance regulators which, while regulating life settlement providers and brokers, do not receive such information as they generally do not have regulatory jurisdiction over these types of investment funds.”

They add, “Life settlement industry participants need to determine whether they are reporting companies or exempt under the CTA. If they do not fall under one of the exemptions, they will be required to report their beneficial ownership information once the CTA regulations become issued and effective, which could be as early as the end of the first quarter of 2022, but more likely the third quarter of 2022.”

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