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FCA fines JLT Specialty £7.8m over Colombia inducements

Regulator fines broker after money paid via JLT Colombia to third-party introducer based in Panama used to bribe government officials at a state-owned insurer

London market broker failed to manage risk of bribery and corruption in relation to payments made through its Colombian operations between 2013 and 2017

The Financial Conduct Authority (FCA) has fined JLT Specialty more than £7.8m ($9.6m) for financial crime control failings in relation to business placed by sister operations in Colombia.

The London market broker, which has since between acquired by Marsh McLennan, was fined a total of £7,881,700 for failing to manage the risks of bribery and corruption associated with a third-party overseas introducer.

In one instance these failures allowed bribery of more than $3m to take place, the regulator said.

The fine related to business placed by JLT Specialty in the London reinsurance market between 2013 and 2017 for JLT Re Colombia, another company in the JLT group.

During this time, JLT Specialty paid $12.3m in commission to JLT Re Colombia, which in turn paid $10.8m to a third-party introducer based in Panama. This introducer then paid more than $3m to government officials at a state-owned insurer to help retain and secure business for JLT.

The FCA found JLT Specialty failed to manage its business and risks responsibly and effectively.

“Lax controls by JLT Specialty meant, ultimately, money flowed into the pockets of corrupt officials,” Mark Steward, executive director of enforcement and market oversight at the FCA said. “It is because of risks such as this we are maintaining our focus on financial businesses’ financial crime systems, taking action where these firms fall short.”

In setting the fine, the FCA considered JLT Specialty’s self-report in June 2017 and assistance during the investigation.

JLT Specialty also qualified for a 30% reduction as it agreed to settle at an early stage of the investigation.

The FCA previously fined JLT Specialty more than £1.8m in December 2013 for similar risk control failures around overseas introducers and bribery and corruption.       

JLT Group was acquired by Marsh McLennan on April 1, 2019.





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