The Financial Services Authority announced on July 21 that it had fined Willis Limited £6.9million for failings in its anti-bribery and corruption systems and controls.

This is the biggest fine imposed by the FSA in relation to financial crime systems and controls to date. The FSA said that these failings created an unacceptable risk that payments made by Willis to overseas third parties could be used for corrupt purposes.

These fines were imposed under the FSA’s own regulatory regime, not the Bribery Act 2010, which came into force only on 1 July 2011. They serve as a sobering reminder, as if one were needed, of the risks involved in questionable payments and inadequate control procedures. Note that the fines were imposed because of the inadequacy of the procedures, and do not necessarily relate to actual bribery or corruption.

Further details of the matter are available on the FSA website