FSA Fines Willis $11M For Violating Anti-Bribery Controls

Willis Ltd. paid £27 million ($44 million) between Jan. 2005 and Dec. 2009 to overseas third parities "who assisted in the winning and retaining of business from overseas clients, particularly in high-risk jurisdictions," the FSA says.

The FSA points to several incidents.

Between Jan. 2005 and May 2009, the broker did not adequately monitor staff to "ensure that each time it engaged an overseas third party, an adequate commercial rational" was recorded and "sufficient due diligence" carried out over the payments. The FSA notes that policies were improved in 2008, but the firm did not make sure that the staff was implementing those policies.

Also, senior management was not fully informed about the subsidiary's policies to "assess whether bribery and corruption risks were being mitigated effectively."

During its investigation, the FSA says it identified $227,000 in suspicious payments made to two overseas third parities concerning business in Egypt and Russia.

In a statement, Tracey McDermott, acting director of enforcement and financial crime for the FSA comments, says: "Willis Ltd. failed to take the appropriate steps to ensure that payments it was making to overseas third parities were not being used for corrupt purposes."

She says that Willis' actions are "disappointing" because the FSA has made repeated communications on this issue with the industry.

"The action we have taken against Willis Ltd. shows that we believe it is vital for firms not only to put in place appropriate anti-bribery and corruption systems and controls, but also to ensure that those systems and controls are adequately implemented and monitored," McDermott adds.

The FSA notes that Willis fully cooperated in the investigations and receives a 30 percent discount for reaching a settlement in the early stages of the investigation. Without the discount, Willis would have been fined £9.85 million ($16 million).

For its part, Willis Group issued a statement from Brendan McManus, chief executive officer of Willis Ltd., a post he was named to in May, saying: "When we discovered some of our businesses had not got that right in the past, we were swift to engage the FSA toward today's regulatory resolution. Our close co-operation has been recognized by the FSA and we are grateful to them for that. It goes without saying that our compliance framework and its application across the business are now very robust and central to the leadership of the company. We can now move forward, stronger as a result."

Willis is not the first broker to deal with bribery-control allegations for overseas accounts.

Aon Ltd. was fined £5.25 million in 2009 (close to $8 million at the exchange rate at that time) for failing to establish and maintain effective systems and controls from 2005 to 2007.