FCA has fined Sesame Limited £6,031,200 for two failings. A small part of the fine relates to failure to ensure customers received suitable advice about Keydata life settlement policies, and the majority of the fine relates generally to systems and controls failings across its advisory business. The entire fine relates to the way in which the firm supervised its appointed representatives (ARs). FCA found the Keydata failings occurred over a four-year period from 2005 to 2009, and a follow-up review identified greater systems and controls failings between 2010 and 2012. The firm's failure to learn lessons from the Keydata experience meant the problems could have occurred again across a larger range of sales. Its culture implied it regarded the ARs as its customers, with the result it did not properly monitor the ARs' activities to assess whether customers might receive unsuitable advice. FCA was particularly concerned as the firm has 1,220 ARs for which it took regulatory responsibility but patently did not properly monitor their activities for compliance with the rules, nor take action when things went wrong. (Source: FCA Fines £6m for Systems and Controls Failings)