US insurance broking company
Willis Limited has been hit by a £6.9m ($11m) fine by the UK’s
Financial Services Authority (FSA) for failings in its anti-bribery
and corruption systems and controls. The fine is the biggest ever
relating to financial crime systems and controls imposed by the
FSA, and eclipses a £5.25m fine it imposed on US insurance broking
company Aon in 2009 for a similar failing.
Commenting on the fine, the
FSA’s acting director of enforcement and financial crime, Tracey
McDermott, said: “Willis Limited failed to take the appropriate
steps to ensure payments it was making to overseas third parties
were not being used for corrupt purposes. This is particularly
disappointing as we have repeatedly communicated with the industry
on this issue and have previously taken enforcement action for
failings in this area.”
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According to the FSA, between
January 2005 and December 2009 Willis made payments to overseas
third parties who assisted it in winning and retaining business
from overseas clients, particularly in high risk jurisdictions.
These payments totalled £27m. The FSA’s investigation found that up
until August 2008 Willis failed to:
- ensure that it established
and recorded an adequate commercial rationale to support its
payments to overseas third parties; - ensure that adequate due
diligence was carried out on overseas third parties to evaluate the
risk involved in doing business with them; and - adequately review its
relationships on a regular basis to confirm whether it was
necessary and appropriate for Willis Limited to continue with the
relationship.
McDermott concluded: “The
action we have taken against Willis Limited shows that we believe
that it is vital for firms not only to put in place appropriate
anti-bribery and corruption systems and controls, but also to
ensure that those systems and controls are adequately implemented
and monitored.”
