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UK regulator fines Willis for anti-corruption system failings

The UK Financial Services Authority (FSA) has fined Willis £6.895 million ($10.3 million) for failings in its anti-bribery and corruption systems and controls.

It is the biggest fine imposed by the FSA over financial controls and relates to £27 million ($40.5 million) in payments to overseas third parties between January 2005 and December 2009. Payments for business in Egypt and Russia have been reported to the Serious Organised Crime Agency.

The FSA says Willis made the payments to parties who assisted it to win and retain business. It found that up until August 2008 Willis failed to ensure that it established and recorded an adequate commercial rationale to support payments to overseas third parties or ensure adequate due diligence was carried out.

It also failed to adequately review its relationships on a regular basis.

“These failures contributed to a weak control environment surrounding payments to overseas third parties and gave rise to an unacceptable risk that these payments could be used for corrupt purposes, including paying bribes,” the FSA said.

Between January 2005 and May 2009, Willis had failed to adequately monitor its staff to ensure that when it engaged an overseas third party, an adequate commercial rationale had been recorded and sufficient due diligence carried out. Although Willis improved its policies in August 2008, it failed to ensure they were implemented adequately.

In 2009 the FSA fined Aon for failing to take reasonable care to establish and maintain effective systems and controls to counter the risks of bribery and corruption over payments to overseas firms and individuals.