"Lax controls by JLT Specialty meant, ultimately, that money flowed into the pockets of corrupt officials."
JLT is based in the UK and provided insurance broking, risk management and insurance claims services. It was part of JLT Group, which had a number of subsidiaries around the world.
JLT 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 21 November 2013 and 6 June 2017, JLTSL paid $12.3m in commission to JLT Colombia Wholesale, 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.
Mark Steward, executive director of enforcement and market oversight at the FCA, commented: "Lax controls by JLT Specialty meant, ultimately, that money flowed into the pockets of corrupt officials. It is because of risks such as this that we are maintaining our focus on financial businesses’ financial crime systems, taking action where these firms fall short.
"The FCA considered that JLTSL’s self-report in June 2017 and assistance during the investigation, including providing investigators with access to materials from JLT Group’s internal investigation, were mitigating factors when determining the appropriate level of financial penalty."