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, wereinsufficient to prevent corrupt payments related to Jardine Lloyd Thompson’sSouth American business – including an instance of over US$3 million in bribes.Denis O’Connor analyses the lessonsfor careful consideration.
Denis O’Connorisa fellow of both the Institute of Chartered Accountants in England & Walesand the Chartered Institute of Securities and Investment. He was a member ofthe British Bankers’ Association Money Laundering Committee from 2003-10 and amember of the Joint Money Laundering Steering Group’s board and editorial panelbetween 2010 and 2016. He has been a frequent speaker at industry conferenceson financial crime issues, both in the United Kingdom and abroad.
The Financial Conduct Authority has fined JLTSpeciality Limited (JLTSL), an insurance broker, over £7.8 million over poorbribery
controls, including one case where bribes of US$3m were paid. Without acknowledging its repeated weaknesses, the firm would
have received afine of £11,259,000. This fine represented JLTSL’s second regulatory sanctionfor poor bribery controls, as
it had been fined £1,876,000 in 2013 for similarfailings.
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