On 14 November 2014, the FCA published a report on its findings following  a thematic review of management of bribery and corruption risks by UK wholesale insurance intermediaries. Key findings include that (a) most intermediaries in the sample reviewed (10 small or medium sized intermediaries, including 9 Lloyd's brokers) did not adequately manage such risks, (b) only half of the intermediaries adequately identified and assessed those risks across their entire business, (c) the level of due diligence carried out was often inadequate and (d) senior management oversight of bribery and corruption risk management was often weak. The Report also provides examples of good practice identified during the review. The FCA will be updating its guidance on financial crime to include a new chapter on anti-bribery systems and controls for intermediaries and has now published a consultation paper for that purpose.