On 19 March 2014, the FCA issued a Final Notice fining Besso Limited (Besso) £315,000 (Stage 1: 30% discount) for failing to take reasonable care to establish and maintain effective systems  and  controls  for countering the risks of bribery and corruption. In particular, the FCA determined that Besso (i) had limited bribery and corruption policies and procedures in place; (ii) failed to conduct an adequate risk assessment of third  parties  before  entering  into  business  relationships;  (iii)  failed to keep its relationships with third parties under review; (iv) did not adequately monitor its staff to ensure  that  sufficient  due  diligence  had been carried out; and (v) failed to keep adequate records  of  the  anti- bribery and corruption measures taken on its third party account files.