Financial Crime Procedures: A reminder

“Bribery and corruption from overseas payments is an issue we expect all firms to do everything they can to tackle. Firms cannot be complacent about their controls – when we take enforcement action we expect the industry to sit up and take notice."
Tracey McDermott, the Financial Conduct Authority (FCA).

On 19 December 2013, the FCA fined JLT Specialty Limited (JLTSL) nearly £1.9 million for failing to have in place appropriate checks and controls to guard against the risk of corruption when making payments to overseas third parties.

JLTSL, which provides insurance broking and risk management services, was found to have failed to conduct proper due diligence before entering into a relationship with partners in other countries who helped JLTSL secure new business, known as overseas introducers. JLTSL also did not adequately assess the potential risk of new insurance business secured through its existing overseas introducers.

"These failings are unacceptable given JLTSL actually had the checks in place to manage risk, but didn't use them effectively, despite being warned by the FCA that they needed to up their game. Businesses can be profitable but firms must ensure that they take the necessary steps to control the risks in that business," said Tracey McDermott, the FCA's director of enforcement and financial crime.

How we can help
The Moore Stephens Regulatory Compliance team can assist you in ensuring that you have the appropriate financial crime policies and procedures in place and in ensuring that those policies and procedures are embedded in your business practices. Find out more here.

For further information, please contact a member of our team.


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Related links

Helping you combat financial crime factsheet
Regulatory compliance