This is the biggest ever fine imposed by the FSA in relation to financial crime systems and controls. Willis Limited is a leading insurance broker and also deals with actuarial services and risk assessment.
Between January 2005 and December 2009, the company made payments totalling £27m to overseas third parties who assisted Willis Limited in winning business from overseas clients in high risk jurisdictions.
The company also failed to establish an adequate commercial rationale to support its payments, carry out due diligence on overseas third parties and review its relationships to confirm whether it was necessary to continue with the relationship.
During the FSA investigation it was found that payments totaling $227,000 were made to overseas third parties regarding business in Egypt and Russia. These were reported to the Serious Organised Crime Agency.
Tracey McDermott, acting director of enforcement and financial crime, said: “Willis Limited failed to take appropriate steps to ensure that 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.
“The action we have taken against Willlis 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.”
The firm co-operated with the FSA and settled at an early stage of the investigation. This meant the firm qualified for a 30 per cent settlement discount. Without the discount the fine would have been £9.85m.