Compliance Monitor
Insurance broker receives second fine for lax anti-bribery controls
A previous fine, work with a Skilled Person, along with group-wide third-party due diligence and approval processes, were insufficient to prevent corrupt payments related to Jardine Lloyd Thompson's South American business - including an instance of over US$3 million in bribes. Denis O'Connor analyses the lessons for careful consideration.
Denis O'Connoris a fellow of both the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Securities and Investment. He was a member of the British Bankers' Association Money Laundering Committee from 2003-10 and a member of the Joint Money Laundering Steering Group's board and editorial panel between 2010 and 2016. He has been a frequent speaker at industry conferences on financial crime issues, both in the United Kingdom and abroad.

The Financial Conduct Authority has fined JLT Speciality Limited (JLTSL), an insurance broker, over ?7.8 million over poor
bribery controls, including one case where bribes of US$3m were paid. [1] Without acknowledging its repeated weaknesses, the
firm would have received a fine of ?11,259,000. This fine represented JLTSL's second regulatory sanction for poor bribery
controls, as it had been fined ?1,876,000 in 2013 for similar failings.