(Business Law Currents) As allegations of corruption continue to belittle Britain’s anti-sleaze credentials, the FSA has come out fighting, imposing its largest fine to date for financial crime and control failings. In June 2011, the FSA fined Willis Limited, a UK insurance broker, £6.895 million for inadequate anti-bribery and corruptions systems as it turns up the heat on corruption and bribery.
The FSA chose to impose the fine after concluding that Willis Limited had created an unacceptable risk by having made payments to overseas third parties that could be used for corrupt purposes.
The FSA found that between January 2005 and December 2009, Willis Limited made payments to overseas third parties who assisted it in winning and retaining business from overseas clients, particularly in high risk jurisdictions. These payments totaled £27 million which were paid:
Without Willis establishing adequate commercial rationale for the payments;
Without conducting adequate due diligence on the risk of doing business with these third parties;
With no regular review of whether the business relationship was necessary.
