On 14 November 2014, the FCA published the thematic review setting out the findings on how small wholesale insurance intermediaries could manage their bribery and corruption risks. It followed on from the 2010 Report “Anti-bribery and corruption in commercial insurance broking” and found that although half of the intermediaries had started work to assess and manage bribery and corruption risk, many did not adequately manage those risks. Areas of particular focus were the lack of understanding of “risks associated with all parties in the insurance distribution chain” and a lack of meaningful management information to allow senior management to understand the ABC profile of the firm. There are useful reminders of the FCA’s expectations contained within the report. A consultation is on-going which will result in amendments to the Financial Crime Guide.