The UK Financial Services Authority announced on July 21 that it had fined Willis Limited £6.895 million (approximately $11.2 million) for failings in its anti-bribery and corruption systems and controls. This is the biggest fine imposed by the FSA in relation to financial crime systems and controls to date. The FSA said that these failings created an unacceptable risk that payments made by Willis to overseas third parties could be used for corrupt purposes.

Between January 2005 and December 2009, Willis made payments totaling £27 million (approximately $44 million) to overseas third parties who assisted it in winning and retaining business from overseas clients. The FSA investigation found that Willis breached Principle 3 of the FSA’s Principles for Business and the Senior Management Arrangements, Systems and Controls sourcebook (SYSC 3.2.6R) in that Willis failed to...