The failure to have appropriate checks and controls in place breached the FCA’s principle on management and control.
JLTSL also did not adequately assess the potential risk of new insurance business secured through its existing overseas introducers.
JLTSL’s penalty was increased because of its failure to respond adequately either to the numerous warnings the FCA had given to the industry generally or to JLTSL specifically.
Tracey McDermott, the FCA's director of enforcement and financial crime said:
"These failings are unacceptable given JLTSL actually had the checks in place to manage risk, but didn’t use them effectively, despite being warned by the FCA that they needed to up their game. Businesses can be profitable but firms must ensure that they take the necessary steps to control the risks in that business.
"Bribery and corruption from overseas payments is an issue we expect all firms to do everything they can to tackle. Firms cannot be complacent about their controls – when we take enforcement action we expect the industry to sit up and take notice."