United States v. Richard Renzi

IKUTA, Circuit Judge,

specially concurring:

“If it looks like an insurance agency and acts like an insurance agency,” Maj. Op. at 754, it might be a brokerage company whose activities are not covered by 18 U.S.C. § 1033.

Section 1033 is drafted narrowly. It criminalizes conduct by persons who are “engaged in the business of insurance.” 18 U.S.C. § 1033(a)(1). The definition of “business of insurance” is, on its face, limited to activities by insurers. The statute defines the term to mean either “the writing of insurance,” or “the reinsuring of risks,” in both cases, “by an insurer.” 18 U.S.C. §…