FSA has fined Aon £5.25 million for breach of Principle 3 as it did not have appropriate systems and controls to counter the risk of bribery and corruption from making payments to overseas firms and individuals. FSA found Aon did not assess properly the risks involved in dealing with people in various jurisdictions who helped it win business and did not properly train relevant staff. As a result, for nearly three years, the firm made various suspicious payments totalling around US$7 million. Aon co-operated fully with FSA and has treated the matter very seriously since its discovery in 2007, when it made several suspicious transaction reports to SOCA. Margaret Cole said the fine sends a clear message that firms cannot conduct business overseas without having appropriate anti-bribery and corruption systems and controls in place. Although FSA does not believe Aon's conduct was deliberate, it is particularly concerned at the effect of its actions on the integrity of the UK financial sector especially given Aon's key competitive position.