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The Financial Conduct Authority (FCA) has fined insurance broker Besso Limited £315,000 for anti-bribery and corruption systems and control failings in respect of its commission arrangements with third parties.
This case illustrates how the Ministry of Justice (MoJ)'s guiding principles for compliance with the Bribery Act 2010 are permeating through all aspects of regulatory and compliance investigations.
This case also reaffirms the position that low risk business sectors and jurisdictions are not exempt from scrutiny.
In its Final Notice dated 17 March 2014, the FCA found Besso to be in breach of Principle 3 of the FCA's Principles for Business in the period January 2005 to August 2011.
We set out below how the FCA findings correspond to the MoJ's guidance for commercial organisations in respect of the Bribery Act 2010:
Also of interest are the factors that the FCA took into account when determining the appropriate type and level of disciplinary sanction.
This article was written by Rhys Novak.
For more information please contact Rhys on +44 (0)20 7427 6563 or email@example.com