The FCA has fined JLT Speciality Limited (JLT) £1,876,000 (including a 30 per cent discount) for failing to have proper risk management systems and controls in place to counter the risk of bribery and corruption associated with making payments to overseas third parties. JLT, a provider of specialist insurance broking, risk management and claims consulting services, breached Principle 3 of the FCA’s Principles for Businesses.
The FCA found that JLT failed to manage the risks created by overseas payments between 19 February 2009 and 9 March 2012. During this period, JLT received almost £20.7million in gross commission from business provided by overseas introducers and paid them over £11.7million in return.
The FCA found no evidence to suggest that JLT permitted any illicit payment during the period mentioned above. JLT also varied its permissions until such time as the FCA was satisfied that JLT could adequately mitigate the risk of bribery and corruption arising from payments to overseas third parties.
The FCA set JLT’s penalty at a higher level than would otherwise have been the case because of its failure to respond adequately to the previous warnings the FCA had given to both the industry and to JLT.
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