U.K. regulator fines Aon Limited for inadequate anti-bribery controls

The Financial Services Authority (FSA) has fined Aon Limited  £5.25 million (Cdn$9.47 million) for “failing to take reasonable care to establish and maintain effective systems and controls to counter the risks of bribery and corruption associated with making payments to overseas firms and individuals.”
“This is the largest financial crime related fine imposed by the FSA to date,” FSA director of enforcement Margaret Cole said in a press release.
“It sends a clear message to the U.K. financial services industry that it is completely unacceptable for firms to conduct business overseas without having in place appropriate anti-bribery and corruption systems and controls.”
FSA says Aon failed to properly assess the risks involved in its dealings with overseas firms and individuals who helped it win business during the period between Jan. 14, 2005 and Sept. 30, 2007. It also failed to implement effective controls to mitigate those risks, the regulator says.
During this time, FSA says in a release, “the firm made various suspicious payments, amounting to approximately US$7 million, to a number of overseas firms and individuals.”
Aon Ltd cooperated fully with the FSA and agreed to settle at an early stage of the FSA’s investigation. As a result, the firm qualified for a 30% discount under the FSA’s settlement discount scheme. Without the discount the fine would have been £7.5 million (Cdn$13.5 million).
“Since the discovery of its failings in 2007, Aon Ltd and its current senior management have demonstrated that they treat this matter with the utmost seriousness,” FSA noted. “The FSA considers that the pro-active determination of Aon Ltd’s current senior management to identify past issues and improve the firm’s systems and controls in this area is a model of best practice that other firms may wish to adopt.”
The U.K. regulator notes it is currently conducting a thematic review into the adequacy of the systems and controls in place at a number of commercial insurance intermediary firms for preventing illicit payments and inducements particularly through the use of overseas third parties.