PPLI Providers: Who Offers Private Placement Life Insurance

“Who actually sells PPLI?” is the most common question we are asked, and the hardest to answer from public sources. Private placement life insurance is, by definition, not publicly offered. Policies are issued under private placement exemptions to accredited investors and qualified purchasers, offering memoranda are not filed publicly, and most carriers publish nothing at all about the product on their websites. The result is a market where the buyer has less public information than in almost any other part of institutional finance.

This page assembles what can be verified from primary sources — government records, insurance regulators, ratings agencies and carriers’ own regulatory filings — and is explicit about what cannot.

Who writes PPLI for US clients

The most authoritative public list comes from an unlikely place. In February 2024 the US Senate Committee on Finance published Private Placement Life Insurance: A Tax Shelter for the Ultra-Wealthy Masquerading as Insurance. In the course of a critical investigation, the Committee identified the carriers it understood “to be the seven largest providers of PPLI policies to U.S. clients”:

• Lombard International
• Zurich American Life Insurance Company
• The Prudential Insurance Company of America
• Investors Preferred
• John Hancock
• Crown Global Insurance Group
• Pacific Life Insurance Company

Two cautions on that list. First, it is a snapshot from February 2024 and describes size, not quality — the Committee was not endorsing any carrier. Second, it is already out of date in one important respect: Lombard International no longer exists under that name. Its European business was acquired by Utmost Group and renamed Utmost Luxembourg S.A. in October 2025; its US and Bermuda business was sold separately and rebranded Axcelus Financial in January 2024. We trace the full chain in the Lombard International profile.

Outside the US, the market is different again. European and Asian wrapper business is dominated by Luxembourg and Liechtenstein carriers — including Utmost, Swiss Life and Baloise — writing under a regulatory framework that has no US equivalent. A carrier that is significant in Luxembourg may write no US-compliant business at all, and vice versa. Domicile is not a detail; it determines whether a carrier can serve a given family.

Our methodology, stated plainly

We publish no carrier rankings and no “best provider” list. We take the view that such a ranking cannot be produced honestly in this market, for a simple reason: the inputs are not public. No carrier in PPLI publishes its minimum premium, its cost-of-insurance scale, its mortality and expense charge, its platform fee, or its approved investment-manager list. Any published ranking of PPLI carriers is therefore either built on undisclosed commercial relationships, or on assumption.

What can be compared objectively is set out below. Every criterion is one where a primary source exists: a regulator’s register, a ratings agency’s published action, a statutory filing, a solvency report, or a statute. Where we could not verify something, this page and the linked profiles say “not publicly disclosed” rather than estimating.

PPLI.com does not sell insurance, does not act as a broker or agent for any carrier, and receives no commission from any carrier named on this page. Our editorial standards set out how we source and correct this material.

The nine criteria that can be compared

1. Domicile and regulator

The carrier’s domicile determines the law that governs policyholder protection, the investment rules that apply inside the policy, and whether the contract will be recognised where the family lives. It is verifiable: every regulator publishes a register. Luxembourg carriers appear on the Commissariat aux Assurances register; Swiss carriers on FINMA’s list; US carriers with their state department of insurance. Check the register, not the brochure — entity names in this market change more often than most advisers expect.

2. Financial strength ratings — and what they do not measure

A.M. Best defines a Financial Strength Rating as an opinion of an insurer’s “ability to meet its ongoing insurance policy and contract obligations”. S&P describes its Insurer Financial Strength Rating as an opinion “about an insurance organization’s ability to pay its policies and contracts”. Moody’s and Fitch use equivalent formulations.

All four measure claims-paying ability. None measures the investment performance of a separate account, which is where a PPLI policyholder’s money actually sits and where the policyholder, not the carrier, bears the risk. A rating speaks to the death-benefit guarantee, the general account and operational continuity. It is necessary information, not sufficient.

Two practical traps. First, ratings attach to legal entities, not brands. A group may be rated while the subsidiary actually issuing the policy is unrated — and it is the issuing entity the policyholder has a claim against. Second, solvency ratios are not comparable across regimes: the EU Solvency Capital Requirement is calibrated to a 99.5% one-year Value-at-Risk, while the Swiss Solvency Test uses a different measure. A 213% SST ratio and a 161% Solvency II ratio cannot be placed side by side.

3. Separate-account insulation

This is the structural question that matters most, and it is answered by statute rather than by marketing. In the United States, state insurance codes provide that separate-account assets are not chargeable with the liabilities of the general account. Delaware’s formulation at 18 Del. C. § 2932(a)(5) is representative: “that portion of the assets of any such separate account equal to the reserves and other contract liabilities with respect to such account shall not be chargeable with liabilities arising out of any other business the insurer may conduct.” New York uses near-identical language at Insurance Law § 4240(a)(12), as does Nebraska at § 44-402.04.

Read the conditional clause carefully. The protection applies “if and to the extent so provided under the applicable contracts”, and only to the portion of assets equal to the reserves and contract liabilities of that account. It is not a blanket ring-fence, and it depends on the policy document as much as the statute.

Luxembourg takes a different route. Under the Law of 7 December 2015 on the insurance sector, assets representing technical provisions must be deposited with a bank approved by the Commissariat aux Assurances under a tripartite agreement between insurer, bank and regulator — the arrangement the market calls the Triangle of Security. The super privilège gives policyholders a first-ranking claim over that pool; CAA Circular 16/9 states that the privilege “prime tous les autres” once the assets are entered on the permanent inventory. Note what this is and is not: a priority ranking in insolvency over a defined pool of assets. It is not a guarantee fund, and Luxembourg has no policyholder compensation scheme equivalent to the UK FSCS. Investment risk remains entirely with the policyholder.

Liechtenstein achieves a comparable result through a registered special estate under the Insurance Supervision Act, reinforced by Article 275 of the Solvency II Directive, under which insurance claims “take absolute precedence over any other claim” against assets representing technical provisions.

4. Custody

Who holds the assets, and under what agreement, is a distinct question from who insures them. In Luxembourg the depositary must be approved by the CAA, the deposit agreement follows a model tripartite form, and assets must be kept clearly separate from the insurer’s other holdings with no right of set-off. Non-EEA depositaries require a minimum rating of A- (S&P) or A3 (Moody’s). In practice most carriers in this market will work with a client’s existing custodian subject to approval — but no carrier publishes its approved custodian list, so this must be established in diligence.

5. Investment platform and IDF access

An insurance dedicated fund has a precise legal definition, not a marketing one. Treas. Reg. § 1.817-5(f)(2)(i) applies the look-through rule only where all beneficial interests are held by segregated asset accounts of insurance companies and “public access” is available “exclusively through the purchase of a variable contract”. A fund open to outside investors is not an IDF, and holding it can be fatal.

In Luxembourg, investment flexibility is set by the regulator rather than the carrier. CAA Circular Letter 26/1, effective 1 February 2026, replaced the long-standing Circular 15/3 for newly issued contracts. It sets investor categories by premium and securities wealth — Type A from €125,000 premium and €250,000 wealth, through to Type D at €1,000,000 and €2,500,000 — with permitted asset classes widening at each step. Type D permits financial instruments essentially without restriction; the default Type N prohibits hedge funds outright. Because these thresholds are regulatory, they apply equally to every Luxembourg carrier. A carrier that claims broader flexibility than its client’s category permits is describing something the CAA has not authorised.

6. Diversification and investor control

For US-taxpayer policies, two federal constraints bind every carrier equally, and the meaningful difference between carriers is how rigorously each enforces them.

IRC § 817(h) and Treas. Reg. § 1.817-5(b)(1)(i) require that no more than 55% of an account’s value sit in any one investment, 70% in any two, 80% in any three and 90% in any four, tested quarterly. Failure means the contract is not treated as life insurance at all.

The investor control doctrine is the second. Rev. Rul. 2003-91 holds that a policyholder is not the owner of the underlying assets on facts where the holder “cannot select specific investments or communicate with investment advisors”; Rev. Rul. 2003-92 reaches the opposite result where the underlying interests are publicly available. In Webber v. Commissioner, 144 T.C. 324 (2015), the Tax Court applied the doctrine to a private placement variable life arrangement where the policyholder directed the separate account’s investments through a nominally independent manager, and held the policyholder taxable on the income currently. The Senate Finance Committee’s 2024 report observed that these rules are “extremely difficult for the IRS to enforce due to a lack of existing reporting requirements” — which is precisely why a carrier’s own control discipline, not the IRS’s, is what protects the policyholder.

A legitimate diligence question is therefore: what is the carrier’s documented procedure for appointing an investment manager, and what firewall prevents the policyholder communicating with that manager about specific holdings? “Can I choose my own manager?” is not a feature to shop for. It is the fact pattern that lost Webber.

7. Minimum premium

No carrier in this market publishes a PPLI minimum premium. Figures circulating online — commonly $1m to $5m — are market convention, not carrier disclosure, and we do not repeat them as fact. The only published thresholds we could verify are regulatory rather than commercial: the CAA’s €125,000 floor for using a dedicated fund in Luxembourg, and product-specific minimums in PRIIPs Key Information Documents for packaged European contracts, which are not the same thing as a bespoke PPLI policy.

8. Policy economics

Equally undisclosed. Cost of insurance, mortality and expense charges, premium loads, asset-based administration fees and platform charges are set out in an offering memorandum delivered only to eligible investors. The practical consequence for a buyer is that carrier pricing can only be compared through a live proposal process, and only if every carrier is asked to quote on an identical, all-in basis expressed as a percentage of policy assets. Our costs and economics analysis sets out the components to insist on.

9. Cross-border suitability and the §953(d) election

Whether a carrier can serve a given family is a binary, checkable fact. Many European carriers explicitly exclude US persons; some Bermuda entities exclude both US and Bermuda residents. For offshore carriers serving US taxpayers, the relevant question is whether the carrier has made an election under IRC § 953(d) to be treated as a domestic corporation. An electing carrier is taxed as a US insurer, which removes the 1% federal excise tax on premiums and avoids a range of complications for the policyholder. It is a yes-or-no question and should be asked directly.

Eligibility runs the other way too. US private placement policies are sold under Regulation D to accredited investors as defined in 17 CFR § 230.501 — individual net worth above $1,000,000 excluding primary residence, or income above $200,000 (or $300,000 jointly) in each of the two most recent years. Where the underlying fund relies on Investment Company Act § 3(c)(7), investors must also be qualified purchasers under § 2(a)(51), generally $5,000,000 in investments for a natural person.

Carrier research

We are publishing individual profiles as we complete primary-source verification. Each states its sources and flags what could not be verified.

• Lombard International — what happened to it, and which entities hold the business now.
• Swiss Life — group structure, which entity issues, and the 2021 US deferred prosecution agreement.
• Pacific Life — a Senate-named top-seven US provider whose PPLI product disclosure could not be verified in its official materials.

Regulatory record matters, and is checkable

Enforcement history is one of the few genuinely public inputs into carrier diligence, and it is routinely omitted from provider comparisons. Two examples from the carriers profiled here, both drawn from primary records: Lombard International Assurance S.A. was fined €1,682,000 by the Commissariat aux Assurances in a decision dated 10 January 2024 for anti-money-laundering control failures; and in May 2021 Swiss Life Holding AG together with its Luxembourg, Liechtenstein and Singapore subsidiaries entered a deferred prosecution agreement with the US Department of Justice, admitting conduct relating to concealed assets of US taxpayers and paying $77,374,337.

Neither fact determines whether a carrier is suitable today — both concern conduct periods that pre-date current ownership, and both were followed by remediation. They are included because a due-diligence page that omits them is not a due-diligence page. Regulators publish these records: the CAA maintains a sanctions register, the DOJ publishes its agreements, and US state insurance departments publish consent orders and examination reports. They should be checked for any carrier under consideration.

Live legislative risk

Carrier selection now carries a policy dimension. The Senate Finance Committee’s February 2024 report described PPLI as “at least a $40 billion tax shelter used exclusively by a few thousand millionaires and billionaires”. On 13 April 2026 Senator Wyden introduced legislation intended to curtail the tax treatment of PPLI. No such bill has been enacted, and the treatment described on this site reflects law as it currently stands. Families structuring today should ask carriers how existing policies would be handled under a change of law, and should read our analysis of what the proposal actually says.

Frequently Asked Questions

Who offers private placement life insurance?

For US clients, the Senate Finance Committee identified seven largest providers in February 2024: Lombard International, Zurich American Life, Prudential, Investors Preferred, John Hancock, Crown Global and Pacific Life. Lombard International has since been split and sold, and no longer operates under that name. Outside the US, Luxembourg and Liechtenstein carriers including Utmost and Swiss Life dominate the wrapper market.

Which PPLI carrier is best?

We do not publish a ranking, because the information required to build one honestly is not public. No PPLI carrier discloses its minimum premium, charge schedule or investment platform. Any published “best carrier” list in this market rests on undisclosed relationships or on guesswork. Carriers can be compared objectively on domicile, regulator, ratings, separate-account law and §953(d) status — and on pricing only through a live, standardised proposal process.

What is the minimum premium for PPLI?

No carrier publishes one. Commonly quoted figures of $1m to $5m are market convention rather than carrier disclosure. The only verifiable published threshold is regulatory: the Luxembourg CAA requires a minimum €125,000 premium to use a dedicated internal fund.

Does a carrier’s A+ rating protect my investments?

No. Financial strength ratings measure claims-paying ability. In a PPLI policy the separate-account assets are legally insulated from the general account and the investment risk sits with the policyholder, so the rating speaks to the death-benefit guarantee and operational continuity rather than to investment outcomes. Check also which legal entity is rated — a group rating does not necessarily extend to the subsidiary issuing your policy.

How many carriers should be approached?

Three to five, on a standardised request for proposal, with every quote expressed as an all-in annual percentage of policy assets. Because pricing is not public, a competitive process is the only way to establish it.

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Last reviewed 19 August 2026. PPLI.com is independent: we do not sell insurance, represent any carrier, or receive commission from any provider named here. This page is educational and is not legal, tax or insurance advice. To discuss carrier selection for a specific situation, request a confidential consultation.