Compliance Monitor
UNAT DIRECT pays £640,000 for premature call centre sales
Incomplete due diligence on external call centres contracted to sell general insurance products has cost UNAT DIRECT Insurance,
a subsidiary of AIG Inc, £640,000. The FSA penalty relates to non-adherence by the firm to its own Third Party Management
(TPM) policy between 14 January 2005 and 22 March 2007. Despite clear stipulation that “Gaps in the control environment must
be addressed prior to the commencement of a business relationship”, eight of the nine call centres that UNAT appointed in
the relevant period began to sell policies before they had been fully assessed. Telemarketing should have been instructed
not to begin sales until final sign-off on the due diligence but this was not required. In the worst case, the due diligence
was not finished 250 days after selling had begun.