FSA has fined Willis Limited £6.895 million for breach of Principle 3 of the FSA's Principles for Businesses and Rule SYSC 3.2.6 R of the FSA’s Senior Management Arrangements Systems and Controls rules. Between January 2005 and December 2009, Willis Limited made payments of £27 million to non-FSA authorised overseas third parties that assisted the firm in winning business from overseas clients, particularly in high-risk jurisdictions. According to the FSA, Willis Limited failed to:
- ensure that it established and recorded an adequate commercial rationale to support its payments to overseas third parties;
- ensure that adequate due diligence was carried out on overseas third parties to evaluate the risk involved in doing business with them;
- adequately review its relationships on a regular basis to confirm whether it was still necessary and appropriate for Willis Limited to continue with the relationship;
- adequately monitor its staff to ensure that each time it engaged an overseas third party an adequate commercial rationale had been recorded and that sufficient due diligence had been carried out; and
- ensure that senior management received sufficient information about the performance of Willis Limited’s relevant policies to allow them to assess whether bribery and corruption risks were being mitigated effectively.