Filers categorized over half of the subjects as policyholders of either the insured, the beneficiary, the payer, or the applicant. The next largest category of subjects was the applicant or owner of an annuity. Consistent with data from all other financial services industries, insurance compa- ny filers most commonly cited “BSA/Money Laundering/Structuring” as the charac- terization of suspicious activity. Structuring, where larger transactions are broken into smaller exchanges, is consistent with an attempt to avoid currency reporting requirements. .
