Zalma on Insurance
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Insurance Claims professional presents articles and videos on insurance, insurance Claims and insurance law for insurance Claims adjusters, insurance professionals and insurance lawyers who wish to improve their skills and knowledge. Presented by an internationally recognized expert and author.
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December 03, 2025
Soldier Sentenced for Nigerian Romance Fraud

Guilty of Money Laundering Scheme
Post 5238

See the video at https://lnkd.in/gqh7V46x and at https://lnkd.in/gmE-zrDC and at https://zalma.com/blog plus more than 5200 posts.

Prison Sentence for Fraud Must be Limited to the Fraud in Which the Defendant Participated

In United States v. Stephen O. Anagor, No. 2:24-CR-00019-DCLC-CRW (E.D. Tenn., Nov. 26, 2025) by Judge Clifton L. Corker the government sought to increase the defendant’s sentence because his co-conspirators added a fraudulent FBI scam that resulted in the victim’s suicide. Anagor sought a lower sentence because he was only involved in part of the fraud.

Charges & Plea

Defendant, a U.S. Army soldier pled guilty on June 11, 2025 to Conspiracy to Commit Mail and Wire Fraud, Aiding and Abetting Aggravated Stalking Resulting in Death and Aiding and Abetting Aggravated Identity Theft that was part of a larger 38-count superseding indictment against Anagor and co-defendants Chinagorom Onwumere and Salma Abdalkareem for an international Nigerian-based romance-scam + follow-on “law-enforcement extortion” scheme.

Role of Anagor

Anagor recruited co-defendant Onwumere into the money-laundering side of the scam and received victim checks in the mail, deposited them into his own U.S. bank accounts, kept a cut, and wired the rest overseas (primarily to Nigeria).

Anagor purchased and sent flowers/gifts to victims to maintain the illusion of romance, knew the funds were proceeds of romance-scam fraud but did not know the specific communications with victims and was not aware that Nigerian co-conspirators were running a secondary “impersonate the FBI/Attorney General” extortion scheme on top of the romance scam.

Key Victim (Victim 1) & Tragic Outcome

An elderly retired teacher from Jonesborough, TN believed he was in a romantic relationship with a celebrity. Nude photos from scammers in Nigeria then switched to impersonating federal law enforcement, threatened exposure/arrest, and extorted $97,500 (his entire life savings) via checks and cashier’s checks sent to Onwumere/Abdalkareem.

After paying, the retired teacher faced continued threats that escalated to the point that Victim 1 sent suicidal messages to the scammers (thinking they were the “celebrity”) and on October 23, 2023 Victim 1 committed suicide.

Anagor knew Victim 1 was being targeted (saw his name and the laundering accounts in WhatsApp messages) and personally received $33,430 that originated from Victim 1’s money laundered through Onwumere/Abdalkareem, but he did not know about the law-enforcement impersonation, the threats, or the suicidal messages.

KEY LEGAL TAKEAWAYS FROM THE OPINION

Relevant Conduct (U.S.S.G. §1B1.3)

Anagor was responsible for the core romance-scam money-laundering activity he agreed to and could reasonably foresee, yet the court concluded he is not responsible for the Nigerian co-conspirators’ separate law-enforcement extortion tactics or knowledge of Victim 1’s suicidal ideation because those were outside the scope of the jointly undertaken activity he signed up for.

2B1.1(B)(16)(A) “Conscious Or Reckless Risk Of Death” In Fraud Cases

The statute requires either (i) subjective awareness, or (ii) objective recklessness. In the Sixth Circuit, the risk must be “actual, not conjectural.”

Mere participation in a romance scam that tragically ends in suicide is not enough for the enhancement when the defendant was unaware of the specific threats or victim’s mental state.

BOTTOM LINE

As of November 26, 2025, the court rejected the government’s attempts to add +4 levels to the fraud guideline calculation. The original (lower) offense level stands going into the December 2, 2025 sentencing hearing, where the court will still consider possible upward variances under 18 U.S.C. § 3553(a) because of the victim’s death and the overall egregiousness of the scheme.

ZALMA OPINION

Fraud schemes based in Nigeria have been rampant since I obtained adulthood in the 1960’s with even my older brother almost became a victim. Anagor, while serving as a soldier in the US Army participated in a fairly successful money laundering scheme by convincing an elderly man into a romance scam where he was led to believe he had a romantic involvement with a celebrity. The scheme went bad when they Nigerians claimed to be FBI agents who threatened him with arrest until he paid his life savings to the fraudsters. Anagor was allowed to be sentenced for the money laundering but not the FBI scheme that resulted in the victim’s suicide. He will be sentenced but not enhanced.

(c) 2025 Barry Zalma & ClaimSchool, Inc.

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December 24, 2025
Common Sense Ruling Protects Insured and Insurer

Marine Insurer May Dispose of Vessel to Avoid Waste
Post 5249

Read the full article at https://lnkd.in/gfn_UHdp, see the video at https://lnkd.in/gDWVccnr and at https://lnkd.in/gv9nsBqk, and https://zalma.com/blog plus more than 5200 posts.

In Western World Insurance Company v. The Estate Of Shawn Arsenault, No. 25-cv-13413-PGL, United States District Court, D. Massachusetts (December 17, 2025) the USDC was asked to resolve a marine insurance dispute after the sinking of the F/V Seahorse, a commercial fishing vessel, off Cape Cod on June 8, 2025. The vessel’s owner and operator, Shawn Arsenault, died in the incident.

Western World Insurance Company issued a hull insurance policy for the vessel. With no personal representative yet appointed for the estate, the insurer cannot determine the proper payee for the insurance proceeds.

The insurer paid for the vessel’s recovery and removal, and the vessel is now with a salvage company, incurring substantial storage fees. The insurer determined the loss is covered under the ...

00:06:27
December 24, 2025
Common Sense Ruling Protects Insured and Insurer

Marine Insurer May Dispose of Vessel to Avoid Waste
Post 5249

Read the full article at https://lnkd.in/gfn_UHdp, see the video at https://lnkd.in/gDWVccnr and at https://lnkd.in/gv9nsBqk, and https://zalma.com/blog plus more than 5200 posts.

In Western World Insurance Company v. The Estate Of Shawn Arsenault, No. 25-cv-13413-PGL, United States District Court, D. Massachusetts (December 17, 2025) the USDC was asked to resolve a marine insurance dispute after the sinking of the F/V Seahorse, a commercial fishing vessel, off Cape Cod on June 8, 2025. The vessel’s owner and operator, Shawn Arsenault, died in the incident.

Western World Insurance Company issued a hull insurance policy for the vessel. With no personal representative yet appointed for the estate, the insurer cannot determine the proper payee for the insurance proceeds.

The insurer paid for the vessel’s recovery and removal, and the vessel is now with a salvage company, incurring substantial storage fees. The insurer determined the loss is covered under the ...

00:06:27
December 24, 2025
Punching a Person In the Head is not an "Occurrence"

Admitting to the Crime of Battery Establishes Intent

Read the full article at https://www.linkedin.com/pulse/punching-person-head-occurrence-barry-zalma-esq-cfe-8fegc, see the video at and at and at https://zalma.com/blog plus more than 5200 posts.

“Everybody has a plan until they get punched in the mouth.” – Mike Tyson

In Jesse De Chacon and Laura Greer v. Caesars Entertainment Corp., Caesars Atlantic City and Bally's Atlantic City, and Michael Nieves and United Services Automobile Association, No. A-2376-23, Superior Court of New Jersey, Appellate Division (December 16, 2025)’’ the appellate court was asked to resolve a dispute over coverage for a battery by its insured on the plaintiff.

KEY FACTS

The Incident:

On September 16, 2018 at Bally's Casino in Atlantic City, New Jersey, Michael Nieves punched Jesse De Chacon once in the head after De Chacon allegedly harassed and grabbed ...

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December 15, 2025
Zalma’s Insurance Fraud Letter – December 15, 2025

Zalma’s Insurance Fraud Letter

Read the full article at https://lnkd.in/dG829BF6; see the video at https://lnkd.in/dyCggZMZ and at https://lnkd.in/d6a9QdDd.

ZIFL Volume 29, Issue 24

Subscribe to the e-mail Version of ZIFL, it’s Free! https://visitor.r20.constantcontact.com/manage/optin?v=001Gb86hroKqEYVdo-PWnMUkcitKvwMc3HNWiyrn6jw8ERzpnmgU_oNjTrm1U1YGZ7_ay4AZ7_mCLQBKsXokYWFyD_Xo_zMFYUMovVTCgTAs7liC1eR4LsDBrk2zBNDMBPp7Bq0VeAA-SNvk6xgrgl8dNR0BjCMTm_gE7bAycDEHwRXFAoyVjSABkXPPaG2Jb3SEvkeZXRXPDs%3D

Zalma’s Insurance Fraud Letter (ZIFL) continues its 29th year of publication dedicated to those involved in reducing the effect of insurance fraud. ZIFL is published 24 times a year by ClaimSchool and is written by Barry Zalma. It is provided FREE to anyone who visits the site at http://zalma.com/zalmas-insurance-fraud-letter-2/

Zalma’s Insurance Fraud Letter

Merry Christmas & Happy Hannukah

Read the following Articles from the December 15, 2025 issue:

Read the full 19 page issue of ZIFL at ...

October 31, 2025
The Zalma Philosophy of Claims Handling – Part 9

The Professional Claims Handler
Post 5219

Posted on October 31, 2025 by Barry Zalma

An Insurance claims professionals should be a person who:

Can read and understand the insurance policies issued by the insurer.
Understands the promises made by the policy.
Understand their obligation, as an insurer’s claims staff, to fulfill the promises made.
Are competent investigators.
Have empathy and recognize the difference between empathy and sympathy.
Understand medicine relating to traumatic injuries and are sufficiently versed in tort law to deal with lawyers as equals.
Understand how to repair damage to real and personal property and the value of the repairs or the property.
Understand how to negotiate a fair and reasonable settlement with the insured that is fair and reasonable to both the insured and the insurer.

How to Create Claims Professionals

To avoid fraudulent claims, claims of breach of contract, bad faith, punitive damages, unresolved losses, and to make a profit, insurers ...

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October 20, 2025
The Zalma Philosophy of Claims Handling – Part I

The History Behind the Creation of a Claims Handling Expert

The Insurance Industry Needs to Implement Excellence in Claims Handling or Fail
Post 5210

This is a change from my normal blog postings. It is my attempt. in more than one post, to explain the need for professional claims representatives who comply with the basic custom and practice of the insurance industry. This statement of my philosophy on claims handling starts with my history as a claims adjuster, insurance defense and coverage lawyer and insurance claims handling expert.
My Training to be an Insurance Claims Adjuster

When I was discharged from the US Army in 1967 I was hired as an insurance adjuster trainee by a professional and well respected insurance company. The insurer took a chance on me because I had been an Army Intelligence Investigator for my three years in the military and could use that training and experience to be a basis to become a professional insurance adjuster.

I was initially sat at a desk reading a text-book on insurance ...

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