While the Financial Services Authority (FSA) may not have set out to make a point, by imposing a record £7 million fine against one of the UK’s leading insurance brokers over suspect corruption activities, they have done just that. The UK Bribery Act just came into enforcement less than a month ago, and with the settlement against Willis Limited, the government has officially taken the leash off the dog. This should be a real eye-opener for British enterprises – take off the blind fold now!
In announcing the penalty, the FSA says that Willis “failed to take appropriate steps to ensure that payments were not being used for corrupt purposes, despite repeated warnings about potential corruption in the industry.” Simply put, the “repeated warnings” should have been heeded. The company should have realised that the FSA was looking at them, and they should have known enough about the Bribery Act to know that the dog was barking right at them.
To their credit, Willis fully cooperated and received a reduced penalty as a result. And, according to a statement by their CEO, Willis has learned a lesson from this and is working to improve their compliance initiatives.
Still, this case shines a light directly on one of the key reoccurring phrases we’ve heard regarding the UK Bribery Act – appropriate steps. That is, the FSA says that Willis didn’t do all they could, and certainly not enough, to curtail foreign corruption. Their anti-corruption systems were insufficient to prevent a big financial hit. Companies would do well to listen to that barking dog.