The Financial Conduct Authority (FCA) recently fined JLT Specialty Limited (JLTSL) more than £1.8 million for failing to maintain appropriate checks and controls to guard against the risk of bribery or corruption when making payments to overseas third parties.

The Financial Conduct Authority (FCA) recently fined JLT Specialty Limited (JLTSL) more than £1.8 million for failing to "have in place appropriate checks and controls to guard against the risk of bribery or corruption when making payments to overseas third parties.”

JLT is a corporate insurance broker that was making payments to introducers who introduced highly risky business. JLT took on such business without carrying out appropriate 'due diligence' on those introducers and their potential links to the introduced parties and the risk of bribery inherent in those relationships. Its sins included a failure to complete risk-assessments properly according to its revised anti-bribery policy and the acceptance of business from state-owned companies in highly risky jurisdictions without carrying out appropriate 'due diligence' on the introducers’ connections with the new clients.

On the 'to do' list are the following:

• Check that your anti-bribery policy explicitly covers payments to business introducers wherever your firm or group is using them.
• Check that the anti-bribery policy contains risk-based 'due diligence' on the nature of the relationship between the introducer and the client being introduced.
• Check that guidance and procedures exist that describe the steps an employee must take to show that he has completed appropriate due diligence and that he has assessed and offset the revealed risks.
• Check that systems used to detect 'politically exposed persons' or PEPs are applied to directors and beneficial owners of introducers, that the operators are properly trained and supervised and the output monitored and considered.
• Check that forms and other 'assessment documents' required under the policy/procedures are completed and negative results escalated to management for action.