Exhibit 8.1
                              MAYER, BROWN & PLATT

                           190 South La Salle Street

                          Chicago, Illinois 60603-3441

                                January 15, 2002


Mutual Risk Management Ltd.
44 Church Street
Hamilton HM 12 Bermuda


     Re:  Mutual Risk Management Ltd.
          Registration Statement on Form S-3
          ----------------------------------

Gentlemen:

     We have acted as counsel to Mutual Risk Management Ltd., a Bermuda
corporation (the "Company"), in connection with the preparation and filing with
the Securities and Exchange Commission under the Securities Act of 1933, as
amended (the "Act"), of a registration statement on Form S-3 (the "Registration
Statement") relating to the registration of common shares of the Company, par
value $0.01 per share, that may be sold from time to time in one or more
offerings up to a total dollar amount of $200,000,000 of common shares. In this
connection, we have examined and are familiar with the Registration Statement,
and in addition have examined such corporate and other records, instruments,
certificates and documents as we considered necessary to enable us to express
this opinion.

     In rendering the opinion set forth in the paragraph below, we have relied
upon the Internal Revenue Code of 1986, as amended (the "Code"), legislative
history, Treasury regulations, judicial authorities, published positions of the
Internal Revenue Service (the "IRS") and such other authorities as we have
considered to be relevant. No tax rulings will be sought from the IRS with
respect to any of the matters discussed herein.

     Based on the foregoing, we hereby confirm that, subject to the limitations
set forth therein, the discussion set forth in the Registration Statement under
the caption "Tax Matters" (other than under the subcaption "Taxation of the
Company - Bermuda") as to United States federal income tax law (excluding any
statements as to the Company's beliefs and conclusions as to the application of
such tax laws to the Company), insofar as such statements constitute summaries
of U.S. legal matters referred to therein, fairly present the information
required to be shown with respect to such legal matters and fairly summarize the
matters referred to therein in all material respects.

     We consent to the filing of this opinion as an exhibit to the Registration
Statement and to the reference to us under the caption "Tax Matters" in the
Registration Statement. We are admitted to practice law in the State of Illinois
and we express no opinions as to matters under or involving any laws other than
the federal law of the United States of America.

                                            Sincerely,

                                            /s/ Mayer, Brown & Platt

                                            Mayer, Brown & Platt

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