FSA has published the interim findings of its review on controls in commercial insurance brokers to counter bribery and corruption. It found good practices but also has concerns, including:  

  • weak due diligence and monitoring of third-party relationships, often based on “market views”;  
  • many firms conducted a review following the Aon fine (they did not following an earlier FSA Dear CEO letter) and found major failings;  
  • although firms appointed MLROs, none had made a SAR;  
  • few firms use a risk-based approach;  
  • firms often do not verify information; and  
  • staff vetting and training is relatively weak and some remuneration systems need attention.