Client Alert

Willis Limited Hit with Record Fine for Failure of Anti-Corruption Controls

August 22, 2011

The Global Compliance and Disputes Practice

The recent fine of £6.895 million levied by the UKs Financial Services Authority (FSA) against insurance broker Willis Limited, a subsidiary of Willis Group Holdings, (Willis) represents the largest penalty imposed by the FSA in its history for inadequate financial crime systems and controls. The action, which pre-dates the effective date of the UKs Bribery Act 2010 (the Bribery Act), relates to conduct in breach of Principle 3 of the FSAs Principles for Businesses Sourcebook and Rule SYSC 3.2.6 R of the FSAs Senior Management Arrangements, Systems and Controls Sourcebook of the FSA Handbook .

Willis is one of the leading insurance and re-insurance brokers in the London market with clients in the marine, aerospace, construction, and energy industries. Willis also engages in reinsurance, risk management, and financial and human resource consulting. The record penalty follows the FSAs publication of the results of its eighteen-month investigation into anti-bribery and corruption in the commercial insurance banking industry in May 2010 and demonstrates the continued attention of the FSA in this area.

The FSAs 24 page Final Notice and related press release set out the facts of the Willis case and contain valuable lessons for the financial services industry.

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