In late 2008 the Financial Services Authority began a review of anti-bribery and corruption systems and controls in commercial insurance broker firms. It has been looking at the measures taken by brokers against the risk that payments made to foreign firms and individuals may in fact be bribes paid to win business from overseas clients, particularly in high risk jurisdictions. The FSA published its interim findings in September 2009 ( and reported that due diligence and monitoring of third-party relationships and payments were generally very weak. The final report is expected soon.