The UK’s Financial Conduct Authority (FCA) fined Besso Limited £315,000 ($520,000) for its failure to take reasonable care to establish and maintain effective systems designed to prevent and detect bribery and corruption risks.
The company, a general insurance broker, maintained weak controls that “gave rise to an unacceptable risk that payments made by Besso to third parties could be used for corrupt practices, including paying bribes to persons connected with the insured or public officials,” the FCA said in its published findings.
Besso’s breaches occurred between 2005 and 2011. They included the following:
- The company had limited bribery and corruption policies and procedures in place until written ones were created in November 2009. The 2009 policies weren’t adequate in their content or implementation.
- Besso failed to conduct adequate risk assessments of third parties before entering into business relationships with them.
- It didn’t carry out adequate due diligence of third parties to evaluate the risks involved in doing business with them.
- It failed to establish and record an adequate commercial rationale to support payments to third parties.
- It didn’t maintain adequate records of the anti-bribery and corruption measures taken on its third-party account files.
In 2009, the FCA sanctioned another insurance broker, Aon, for similar failings regarding third-party business risk controls, fining it £5.25 million ($8.6 million).
Besso issued a statement Wednesday to clarify that the FCA “has not said that Besso permitted any illicit payments or inducement to any such third party,” the Financial Times reported.
By agreeing to a settlement at an early stage of the FCA’s investigation, Besso qualified for a 30 percent discount.
Julie DiMauro is the executive editor of FCPA Blog and can be reached here.