Policy and practice of equal importance for FCA compliance

By Andrew Northage

In late December 2013, the Financial Conduct Authority (FCA) fined JLT Specialty £1.87m for failings in its anti-bribery controls in relation to overseas introducers that had assisted it to win and retain insurance business. The fine was reduced from more than £2.68m as a result of JLT agreeing to an early settlement.

JLT is an insurance broking, risk management and claims consulting business and a wholly owned subsidiary of Jardine Lloyd Thompson Group, the largest Europe-based broker quoted on the London Stock Exchange.

Despite the fact that JLT’s due diligence procedures in relation to introducers had been assessed by an external adviser as being comprehensive in September 2011, and that the FCA found no evidence that JLT had either permitted or intended to permit any illicit payment or inducement to any overseas introducers, the FCA fined JLT for failing to use its procedures effectively…

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