The FSA’s £6.9m fine on Willis emphasises how seriously the watchdog is putting pressure on senior managers to ensure adequate anti-bribery and corruption systems and controls, a City lawyer has commented.
Law firm Osborne Clarke partner Tim Boyce said: “The Willis fine shows that the FSA remains focused on getting firms to manage the risk of financial crime, particularly firms operating internationally and making commission payments overseas.
”Like the Aon fine of £5.5m in 2009, it was Willis' lack of systems and controls and management oversight which has caught the FSA's attention - although Willis has reported some suspicious transactions to the Serious Organised Crime Agency, no specific instances of bribery and corruption seem to have been identified.
”This is an area where the FSA has been cracking the whip over commercial insurance intermediaries for some time now. More widely, it is also the latest manifestation of the increasing emphasis the FSA is putting on senior management responsibility in all authorised firms for ensuring adequate systems and controls, whether it’s for preventing financial crime, ensuring suitability of financial products, or protecting client money.”
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