The data revealed some potential trends in illicit activity. Some of the typologies evidenced in the narratives appeared very similar to classical examples of the money laundering stages of layering and integration. 1 For example, subjects sometimes used multiple cash equivalents (., cashier’s checks and money orders) from differ- ent banks and money services businesses to make policy or annuity payments, and then cashed out the insurance products to potentially disguise the original source of the funds. Also, some customers seemed unusually willing to incur significant penalties for surrendering their annuities before full term. .
