Context
The FCA has fined JLT Specialty Limited (JLTSL) £7,881,700 for financial crime control failings, which in one instance allowed bribery of over $3m to take place. The Final Notice gives the detail of the case. This is the second time that JLT has been fined in relation to a lack of financial crime oversight in its distribution chain.
Key points to note
- JLTSL is a UK based insurance broker. It was part of JLT Group plc which has a number of subsidiaries around the world.
- JLTSL placed business in the London reinsurance market for JLT Re Colombia, another company in the JLT group. The business had been introduced by a third-party based in Panama.
- Between 21st November 2013 and 6th June 2017 JLTSL paid $12.3m in commission to JLT Colombia Wholesale Limited, the parent company of JLT Re Colombia, which in turn paid $10.8m to the third-party introducer. This introducer then paid over $3m to government officials at a state-owned insurer in order to help retain and secure their business for JLTSL and JLT Re Colombia.
- The FCA found that JLTSL failed to manage their business and risks responsibly and effectively.
- The FCA previously fined JLTSL £1,876,000 in December 2013 for similar risk control failures around overseas introducers and bribery and corruption.
- In April 2019 JLT Group plc was acquired by Marsh & McLennan Companies, Inc. JLTSL has been non-trading since the sale of its trade, assets and liabilities in 2020.
Next actions
Whilst we have included this item for information and awareness it shows the importance the FCA place upon firms having appropriate policies and procedures in place in relation to financial crime and distribution chain oversight.