The Financial Conduct Authority in the UK (the FCA) has imposed a fine of £8.4 million on a UK authorised non-life insurer for failings concerning outsourced sales of accident insurance products. The FCA took the view that the insurer had breached certain of its rules, including relating to management and control and customer interests. The insurer had outsourced sales and customer services activities to a number of intermediaries, but was found not to have taken reasonable steps to ensure customers were treated fairly. Key concerns identified by the FCA included that the insurer had poor systems and controls, inadequate oversight of outsourced functions, deficient training material, and an inadequately resourced compliance department. Other points identified included that (a) sales were targeted at middle/low income earners not having third level qualifications, to whom insufficient information was provided and (b) sales scripts had been designed by the insurer emphasising the availability of cancellation rights, but the post-sales process made it difficult for customers to cancel. Mitigating factors taken into account by the FCA in determining the fine included the insurer's redress programme and changes to its governance structure, product design, policy documentation and internal policies and procedures. Notably, a 30% discount was applied to the fine as a result of the insurer's early agreement to settle, reducing the fine actually imposed from almost £12 million. The FCA has emphasised that firms must take responsibility for their outsourcing arrangements and ensure that they treat customers fairly.