Captives in Murky Water

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The integrity created through properly established, run, governed and independently audited captives generally speak for itself. Captive boards may wish to appoint an independent consultant to provide assurance that policies, processes and controls are in place to deliver that integrity.

James Portelli

Captives in Murky Water Article Pic

Introduction

BEPS and DAC

On 4th January 2021, the Commissioner for Revenue in Malta issued the ‘Guidelines on the Mandatory Automatic Exchange of Information in relation to Cross-Border Arrangements’ (Article 96(2) of the Income Tax Act (Chapter 123 of the Laws of Malta; S.L 123.127):

These directives emanated from the EU Council Directive 2011/16 (‘Directive on Administrative Cooperation’ or ‘DAC’) as amended in May 2018 by the EU Council Directive 2018/822, referred to as DAC 6. These are a natural progression from the 2015 OECD project on Base Erosion and Profit Shifting (BEPS). DAC 6 is arguably EU’s targeted action towards automatic exchange of tax information. The objective is to bolster tax transparency and attack harmful tax practices in cross-border arrangements.

 

Understandably, captive insurance companies globally, their ultimate beneficiary owners and captive domiciles have been discussing the implications of BEPS since well before the introduction of the EU Directives of 2016 and 2018, and which are being gradually transposed into respective local law within EU member states.

 

Why, or in which instances, would DAC 6 be of concern or interest to captives?

CUP and DAC

Transfer pricing is arguably at the top of the international tax agenda. The ‘Comparable Uncontrolled Price’ when applied to captives touches upon issues relating to the provision of insurance or ‘cash-pooling’ (which broadly falls under the provision of a loan/guarantee or other financial transactions and intra-group services) or on the provision of other intra-group services (e.g. IT, HR, legal, finance etc.).

 

In February 2020 OECD released a report on ‘Transfer Pricing Guidance on Financial Transactions’ and chapter 5 of this report deals specifically with captive insurance arrangements and transfer pricing.

 

The OECD report raises a justification for captives that is unrelated to tax. The prime objective of a captive is to manage intra-group risks in a more economically feasible way than that provided by the conventional insurance market. Tactical advantage may also be derived through the application of captives as a result of cross-border regulatory and fiscal arbitrage (such as accessing outward reinsurance or retrocession, mitigating volatility in premium, deductible levels or differences in policy limits or conditions). However, from a corporate governance perspective, it may be a well-worth exercise for a captive board to ask itself a set of due diligence questions so as not fall foul of this legislation. Some questions immediately come to mind and these are listed under ‘Captive Considerations’ below. Another worthy exercise would be to scrutinise all agreements or interactions within the group under an internal regulatory spotlight.

Nomenclatures and Reporting Requirements

From an insurance perspective, perhaps what one needs to define is what constitutes (and whether we fall under these definitions):

1.               A promoter/intermediary/service provider; and

2.              A reportable arrangement

According to the EU Directive the term:

 

1.               promoter,” is an intermediary who, “designs, markets, organizes or makes available for implementation or manages the implementation of a reportable cross-border arrangement” and

 

2.              service provider,” is an intermediary who, “knows or could be reasonably expected to know that they have undertaken to provide aid, assistance or advice with respect to a reportable cross-border arrangement.”

 

3.              Reportable arrangements/situations may include:

a.     reinsurance transactions with low tax jurisdictions

b.    insurance portfolio transfers with different considerations

c.     cross-border asset liability management arrangements

d.    cross-border life-insurance schemes with tax deferral in exit taxes.

It is worth emphasizing that the term ‘intermediary’ within this context has a completely different interpretation and is unrelated to the meaning of an ‘intermediary’ as defined and regulated under various insurance legislation worldwide. Therefore, within this context, an insurance company (including a captive insurance company) can be an ‘intermediary’ if it is a ‘promoter’ or ‘service provider’ of a ‘reportable arrangement’.

 

Put simply, for example, a captive insurance company supplying intra-group insurance and/or purchasing reinsurance from within the group would be an ‘intermediary’ for the scope of DAC 6. Within the context of companies in Malta, example 3 under 2.4.3 of the CfR guidelines (Malta, 4th January 2021) specifically highlights this.

 

If its activities fall within pre-defined cross-border reportable arrangements or ‘hallmarks’ (whether within the EU or with 3rd-country entities), then the captive insurer, as an ‘intermediary’ is obliged to report these. A typical reportable arrangement or hallmark would be one that is specifically aimed at exploiting a tax advantage.

 

Guidelines state that, irrespective of the tax residence of parties to a reportable cross-border arrangement, a person falling within the definition of an intermediary will have an obligation to file information with the respective revenue authorities only where such person has a ‘nexus’ within the country. For the purpose of establishing ‘nexus’, the intermediary needs to satisfy at least one of the following conditions:

 

1.   Residence for tax purposes;

 

2.   Permanent establishment through which the services are being provided;

 

3.   An entity incorporated within the country, or governed by the its laws;

 

Registration with a professional association related to legal, taxation or consultancy services in the country.

Captive Considerations

From an internal due diligence perspective, it might be pertinent for captive insurance company boards to ask themselves the following, when examining whether it falls within an ‘intermediary’ category or whether an action is a ‘reportable arrangement’:

1.   Is the captive insurance company providing a pooling and further risk-transfer/diversification service? Is this service providing tangible economic benefit (other than fiscal benefits) to its internal client(s)? Is the economic capital position of the parent or other internal entities improving as a result this economic benefit?

2.   Are the captive and its reinsurers all regulated undertakings with substantively similar regulatory regimes vis-à-vis solvency and capital adequacy and disclosure requirements?

3.   Are the risks insured by the captive, ones that are generally insurable by the conventional market? A negative answer to this question may give rise to a discussion along the lines that certain captives have been established specifically to address gaps in the conventional market’s offering. However, provided that one can substantively prove the technical validity of the pricing of the insurance cover being offered, then this question should not pose a problem.

4.  Does the captive insurance company run a real risk of suffering losses?

5. Is the pricing of captive products more or less in line with what its clients would be charged in the conventional market for the same level of insurance cover or policy limits? Some may argue that, for example, lower acquisition or operating costs for a captive may, in theory, justify lower premiums. From a transfer pricing perspective, a risk may exist if the inverse was true, i.e. higher premiums than the conventional market would charge are transferred to the captive and so not commensurate to the risk being insure.

6. If the insurance company provides insurance to third parties adjunct to a product offered by another company within the group (such as auto or technology-related warranty and extended warranty products, GAP etc.), how does its pricing benchmark against conventional competitors?

 

7. Is the captive an entirely ‘managed concern’ or a ‘brass-plate’ or is it in control of, for example, the decision-making (and oversight) of risk acceptance/treatment and of other controlled functions?

 

Conclusion

A brushstroke conclusion for captives established with the core objective of providing insurance solutions to group companies (or their clients) is that they need not be too concerned about the implications or falling foul of DAC 6 and similar legislation as they are aimed at bolstering fiscal accountability and transparency. The integrity created through properly established, run, governed and independently audited captives generally speak for itself. Captive boards may wish to appoint an independent consultant to provide assurance that policies, processes and controls are in place to deliver that integrity.

 

James Portelli | 15th January 2021

 

James is a Chartered Insurance Risk Manager holding a senior executive role in an international insurance undertaking, non-executive directorships and Risk Chair on a portfolio of insurance companies operating in or from Malta by virtue of the EU Freedom of Service Directive. James is also a member of the Cutts-Watson Consulting panel and lectures in insurance programmes at the University of Malta. Views expressed are personal and may not be deemed to constitute advice:

 

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James Portelli CWC

James Portelli

Consultant

A seasoned chartered insurance risk manager with 3 decades of insurance and reinsurance experience in conventional and captive sectors across Europe and the Middle East.
James has been involved in financial services, initially in banking, since 1986 and joining insurance in 1990. 
 
A chartered insurance risk manager, James is a Fellow of the Chartered Insurance Institute and a Fellow of the UK Institute of Risk Management and also holds an MSc in Risk Management from Glasgow Caledonian University. 
 
He started his insurance career with Middlesea Insurance plc (now part of the Grupo Mapfre conglomerate) in Malta later worked in London, Central Europe , the Middle East (Bahrain, UAE and Qatar) and East Africa with a career spanning commercial and industrial insurance underwriting, distribution, outward reinsurance, broking, risk management, captive management, consulting and training.
 
He is now an non-executive director on a portfolio of insurance companies in Malta operating across Europe by virtue of the EU Freedom of Services Directive, is also active in one company in an executive capacity and lectures insurance part-time at the University of Malta. 

James Portelli

Consultant

James Portelli CWC

A seasoned chartered insurance risk manager with 3 decades of insurance and reinsurance experience in conventional and captive sectors across Europe and the Middle East

James has been involved in financial services, initially in banking, since 1986 and joining insurance in 1990. 
 
A chartered insurance risk manager, James is a Fellow of the Chartered Insurance Institute and a Fellow of the UK Institute of Risk Management and also holds an MSc in Risk Management from Glasgow Caledonian University. 
 
He started his insurance career with Middlesea Insurance plc (now part of the Grupo Mapfre conglomerate) in Malta later worked in London, Central Europe , the Middle East (Bahrain, UAE and Qatar) and East Africa with a career spanning commercial and industrial insurance underwriting, distribution, outward reinsurance, broking, risk management, captive management, consulting and training.
 
He is now an non-executive director on a portfolio of insurance companies in Malta operating across Europe by virtue of the EU Freedom of Services Directive, is also active in one company in an executive capacity and lectures insurance part-time at the University of Malta. 

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If you are looking to create, enhance or take to market your captive proposition we can advise you on the best way to proceed. CWC is wholly independently owned and not associated with another broking or insurance company, giving it complete independence and flexibility. This allows us to work with you to deliver to the captive market a best in class offering that benefits from our combined accumulated knowledge and wisdom.

Examples of CWC services for Service Providers:

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If you are considering captive insurance for the first time or need quality independent advice on change management, CWC can assist you ensuring the captive insurance vehicle is right for your organisation.

Examples of CWC services for Captive Owners:

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We do not seek to assume or duplicate responsibilities and activities performed by a Captive Manager. Rather, we look to bring added value to client service and/or assist the Captive Manager’s management of their own business. We bring extensive experience of running a captive management business including strengthening a value proposition, winning business, innovative thinking and developing staff.

Examples of CWC services for Captive Managers:

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Captive Managers

- Stakeholders -

We do not seek to assume or duplicate responsibilities and activities performed by a Captive Manager. Rather, we look to bring added value to client service and/or assist the Captive Manager’s management of their own business. We bring extensive experience of running a captive management business including strengthening a value proposition, winning business, innovative thinking and developing staff.

Examples of CWC services for Captive Managers:

  • Act as a Non Executive Director of clients under management.
  • Assist in responding to RFP’s.
  • Review internal processes and procedures.
  • Facilitate internal workshops or away days to set strategy, establish plans or solve a particular problem.
  • Assist in staff training and education.
  • Assist in development and delivery of marketing and sales plans.
  • Act as challenger or ‘Devil’s Advocate’ to test strategy.
  • Undertake client and employee surveys.
  • Provide market intelligence.
  • Advise on complex or unusual issues or situations that captive managers may not have encountered before.
  • Assist in identifying, and recruitment of, suitable candidates for vacant or newly created senior positions.

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  • xxxxxxxx.

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Dom Wheatley

Consultant

A seasoned captive practitioner and consultant, finance industry experience with over 25 years  world class knowledge.

Exiting Chief Executive of Guernsey Finance, the promotional agency for Guernsey’s finance industry.

His role included business development and the promotion of Guernsey’s finance industry in the Island’s target markets including Europe, the US and the emerging markets, technical research to support promotional activities and liaison with industry associations and government.

Previously Chief Marketing Officer of the Willis Global Captive Practice and Managing Director of its Guernsey business. Over 25 years of finance experience in London and, for the past 19 years in Guernsey.

A member of the Institute of Directors and serve as a non-executive director on a number of local boards. A fellow of the Chartered Insurance Institute and holds an M.B.A from Warwick University.

Dom Wheatley

Consultant

Dominic-Wheatley_CWC_Team

A seasoned captive practitioner and consultant, finance industry experience with over 25 years  world class knowledge.

Exiting Chief Executive of Guernsey Finance, the promotional agency for Guernsey’s finance industry.

His role included business development and the promotion of Guernsey’s finance industry in the Island’s target markets including Europe, the US and the emerging markets, technical research to support promotional activities and liaison with industry associations and government.

Previously Chief Marketing Officer of the Willis Global Captive Practice and Managing Director of its Guernsey business. Over 25 years of finance experience in London and, for the past 19 years in Guernsey.

A member of the Institute of Directors and serve as a non-executive director on a number of local boards. A fellow of the Chartered Insurance Institute and holds an M.B.A from Warwick University.

Ashley-Paxton_CWC_380-450

Ashley Paxton FCA

Project Consultant

Guernsey based chartered accountant with c30 years’ experience spent in practice.

Recently retired as partner and head of Advisory for KPMG in the Channel Islands.

Guernsey based chartered accountant with c30 years’ experience spent in practice.

Unique blend of operational and client experience split between audit and advisory latterly focused on providing transactional support across the insurance, funds, fiduciary and banking sectors as well as local government.

Led a number of high profile and innovative engagements for the States of Guernsey including:

2017 – States bond issue commissioned by the Scrutiny Management Committee
2017 – Guernsey housing market review
2016 – Strategic review of the Guernsey fiduciary industry
2015 – Financial mitigation for milk distributors
2015 – International Capital Flows (funds sector)
Various other confidential engagements

Qualifications
Fellow of the Institute of Chartered Accountants in England and Wales
BSc (Hons) Economics, University of Warwick

Ashley Paxton FCA​

Project Consultant

Ashley-Paxton_CWC_380-450

Guernsey based chartered accountant with c30 years’ experience spent in practice.

Recently retired as partner and head of Advisory for KPMG in the Channel Islands.

Guernsey based chartered accountant with c30 years’ experience spent in practice.

Unique blend of operational and client experience split between audit and advisory latterly focused on providing transactional support across the insurance, funds, fiduciary and banking sectors as well as local government.

Led a number of high profile and innovative engagements for the States of Guernsey including:

2017 – States bond issue commissioned by the Scrutiny Management Committee
2017 – Guernsey housing market review
2016 – Strategic review of the Guernsey fiduciary industry
2015 – Financial mitigation for milk distributors
2015 – International Capital Flows (funds sector)
Various other confidential engagements

Qualifications
Fellow of the Institute of Chartered Accountants in England and Wales
BSc (Hons) Economics, University of Warwick

Graham-Powell_CWCTeam

Graham Powell

Consultant

Graham has spent four decades working in the insurance industry. He has a wealth of experience in all aspects of an insurer’s life cycle including feasibility, formation, management, revalidation and de-risking. In recent years Graham has specialized more on regulatory and compliance work for commercial insurers.

Based in Guernsey, Graham brings his unique skill-set CWC working centrally with the team as it responds to the diverse and ever-changing needs of its clients.

Graham has made his career in the Guernsey finance industry. For more than 35 years he held a senior position at the largest and most innovative captive manager in Europe. As a practitioner, Graham’s own diverse portfolio of clients were accustomed to 1) new ideas and techniques being introduced on a regular basis and 2) no stone being left unturned in the unceasing quest for new lines of business.

As a result of so many years at the “coal face” Graham has a unique insight into every aspect of insurance management. This wealth of experience is now channeled into helping CWC’s clients realise the full potential of their insurers.

Outside of CWC, Graham also acts as an independent director on a number of Guernsey regulated and non-regulated boards of entities for groups operating in a wide range of industries. The owners of these groups range from private individuals to constituents of the FTSE 100.

Graham is a Chartered Insurance Practitioner and a Fellow of the Chartered Insurance Institute by examination. He is registered and approved as a Director with the Guernsey Financial Services Commission.

Graham Powell

Consultant

Graham-Powell_CWCTeam
Graham has spent four decades working in the insurance industry. He has a wealth of experience in all aspects of an insurer’s life cycle including feasibility, formation, management, revalidation and de-risking. In recent years Graham has specialized more on regulatory and compliance work for commercial insurers.

Based in Guernsey, Graham brings his unique skill-set CWC working centrally with the team as it responds to the diverse and ever-changing needs of its clients.

Graham has made his career in the Guernsey finance industry. For more than 35 years he held a senior position at the largest and most innovative captive manager in Europe. As a practitioner, Graham’s own diverse portfolio of clients were accustomed to 1) new ideas and techniques being introduced on a regular basis and 2) no stone being left unturned in the unceasing quest for new lines of business.

As a result of so many years at the “coal face” Graham has a unique insight into every aspect of insurance management. This wealth of experience is now channeled into helping CWC’s clients realise the full potential of their insurers.

Outside of CWC, Graham also acts as an independent director on a number of Guernsey regulated and non-regulated boards of entities for groups operating in a wide range of industries. The owners of these groups range from private individuals to constituents of the FTSE 100.

Graham is a Chartered Insurance Practitioner and a Fellow of the Chartered Insurance Institute by examination. He is registered and approved as a Director with the Guernsey Financial Services Commission.

Paul-Wakefield-CWCTEAM

Paul Wakefield

Consultant

Longstanding experience in on & offshore environments most recently as a Non Executive Director with a London market insurance Company. Experienced in feasibility studies, regulatory matters and the set up of insurance subsidiaries for global multi national corporations.

Paul delivers his own in-depth market knowledge of, and insight into, the captive insurance world.

Paul brings longstanding experience of working in both onshore and offshore environments, most recently as a Non Executive Director with a London market insurance company.

He is also currently a Non Executive Director of a number of Guernsey based insurance companies. He provides CWC clients with further valuable knowledge and a proven track record of strategic and operational consulting.

Paul has undertaken numerous feasibility studies and set up insurance subsidiaries for multi- national corporations across the globe.

As part of the work with captives he has overseen portfolio transfers, novations, redomiciliation of captives, Protected Cell Company formation and the design and implementation of multi-year multi-line reinsurance programmes. He also has undertaken various consultancy work on the regulatory side of insurance.

Paul is an Associate of the Chartered Insurance Institute. He is registered and approved as a Director with the UK Prudential Regulatory Authority and the Guernsey Financial Services Commission.

Paul Wakefield

Consultant

Paul-Wakefield-CWCTEAM
Longstanding experience in on & offshore environments most recently as a Non Executive Director with a London market insurance Company. Experienced in feasibility studies, regulatory matters and the set up of insurance subsidiaries for global multi national corporations.

Paul delivers his own in-depth market knowledge of, and insight into, the captive insurance world.

Paul brings longstanding experience of working in both onshore and offshore environments, most recently as a Non Executive Director with a London market insurance company.

He is also currently a Non Executive Director of a number of Guernsey based insurance companies. He provides CWC clients with further valuable knowledge and a proven track record of strategic and operational consulting.

Paul has undertaken numerous feasibility studies and set up insurance subsidiaries for multi- national corporations across the globe.

As part of the work with captives he has overseen portfolio transfers, novations, redomiciliation of captives, Protected Cell Company formation and the design and implementation of multi-year multi-line reinsurance programmes. He also has undertaken various consultancy work on the regulatory side of insurance.

Paul is an Associate of the Chartered Insurance Institute. He is registered and approved as a Director with the UK Prudential Regulatory Authority and the Guernsey Financial Services Commission.

Niall_Lucas_CWCTeam

Niall Lucas

Consultant

Niall has spent most of his professional career in the captive insurance industry. Holds the ACII, FPC & Chartered Insurer along with various accounting, marketing & computer vocations.

Niall has spent most of his professional career in the captive insurance industry.

He started in Guernsey in 1996, where he provided underwriting support the UK Post Office captive.

During his career, Niall has advised captive stakeholders on underwriting, strategic, operational and governance matters across a broad range of industries and jurisdictions.

He has lead difficult consulting projects requiring innovative thinking, high quality communication skills and perseverance.

Niall has exceptional IT knowledge with highly developed research and analytical skills and qualified as a Chartered Insurer and Financial Planner. These attributes together with his vast captive experience allows Niall to fulfill his role as Chief Operating Officer of CWC.

Niall joined CWC in 2015 to support Malcolm in the development of the company. In 2016 he was promoted to COO as CWC continues to grow.

Niall Lucas

Chief Operating Officer

Niall_Lucas_CWCTeam

Niall has spent most of his professional career in the captive insurance industry. Holds the ACII, FPC & Chartered Insurer along with various accounting, marketing & computer vocations.

Niall has spent most of his professional career in the captive insurance industry.

He started in Guernsey in 1996, where he provided underwriting support the UK Post Office captive.

During his career, Niall has advised captive stakeholders on underwriting, strategic, operational and governance matters across a broad range of industries and jurisdictions.

He has lead difficult consulting projects requiring innovative thinking, high quality communication skills and perseverance.

Niall has exceptional IT knowledge with highly developed research and analytical skills and qualified as a Chartered Insurer and Financial Planner. These attributes together with his vast captive experience allows Niall to fulfill his role as Chief Operating Officer of CWC.

Niall joined CWC in 2015 to support Malcolm in the development of the company. In 2016 he was promoted to COO as CWC continues to grow.

Conor_Jennings_CWC_Team

Conor Jennings

Consultant

Conor Jennings FCII, FIRM, TEP is an insurance and risk management professional of many years’ experience.

He has lived and worked in Ireland, UK, Asia, Guernsey, BVI and more recently in the Cayman Islands.

During this time Conor has managed and directed captive insurance companies for clients ranging from small, family-held businesses to US Fortune 500 companies encompassing a whole host of industries.


Having, most recently, spent over a decade in the Caribbean managing mainly North and South American captive insurance clients Conor leverages his deep global knowledge and skills set to provide creative risk financing solutions to clients from all over the world.

Conor Jennings

Consultant

Conor_Jennings_CWC_Team

Conor Jennings FCII, FIRM, TEP is an insurance and risk management professional of many years’ experience.

He has lived and worked in Ireland, UK, Asia, Guernsey, BVI and more recently in the Cayman Islands

During this time Conor has managed and directed captive insurance companies for clients ranging from small, family-held businesses to US Fortune 500 companies encompassing a whole host of industries.

Having, most recently, spent over a decade in the Caribbean managing mainly North and South American captive insurance clients Conor leverages his deep global knowledge and skills set to provide creative risk financing solutions to clients from all over the world.

Malcolm-Cutts-Watson_CWC

Malcolm Cutts-Watson

Founder & Managing Director

A seasoned captive practitioner and consultant, Malcolm has gathered vast experience over 4 decades working in different domiciles and advising companies and regulatory bodies across the world.

Malcolm Cutts-Watson has spent most of his professional career in the captive insurance industry.

He started in Bermuda in 1982, was in the vanguard of the development of Vermont captive business and then worked in Guernsey. During his career, Malcolm has advised captive stakeholders on strategic, operational and governance matters across a broad range of industries and jurisdictions . He also advises governmental and regulatory bodies on legislative and regulatory change.

He has served, and continues to serve, as a director on a variety of captive insurers and is an approved person in many captive domiciles. He qualified as an accountant in 1982.

Malcolm was a member of the Captive Review Power 50 and in 2015 received the industry’s outstanding contribution by an individual award.

In 2017 he became an inaugural inductee into the Captive Hall of Fame which recognises the most influential figures in the captive industry over the past 50 years.

He has acted as industry partner to AIRMIC’s Captive Special Interest Group. He is a regular contributor to industry debate and is a passionate advocate for the raising of standards in the captive industry.

Malcolm founded CWC in 2015 to allow organisations access to the accumulated knowledge, insight and solutions that he, and the rest of the CWC team of captive insurance experts, have gathered over their lifetimes.

Malcolm Cutts-Watson

Founder & Managing Director

Malcolm-Cutts-Watson_CWC

A seasoned captive practitioner and consultant, Malcolm has gathered vast experience over 4 decades working in different domiciles and advising companies and regulatory bodies across the world.

Malcolm Cutts-Watson has spent most of his professional career in the captive insurance industry.

He started in Bermuda in 1982, was in the vanguard of the development of Vermont captive business and then worked in Guernsey. During his career, Malcolm has advised captive stakeholders on strategic, operational and governance matters across a broad range of industries and jurisdictions . He also advises governmental and regulatory bodies on legislative and regulatory change.

He has served, and continues to serve, as a director as a director on a variety of captive insurers and is an approved person in many captive domiciles. He qualified as an accountant in 1982.

Malcolm was a member of the Captive Review Power 50 and in 2015 received the industry’s outstanding contribution by an individual award.

In 2017 he became an inaugural inductee into the Captive Hall of Fame which recognises the most influential figures in the captive industry over the past 50 years.

He has acted as industry partner to AIRMIC’s Captive Special Interest Group. He is a regular contributor to industry debate and is a passionate advocate for the raising of standards in the captive industry.

Malcolm founded CWC in 2015 to allow organisations access to the accumulated knowledge, insight and solutions that he, and the rest of the CWC team of captive insurance experts, have gathered over their lifetimes.