Overview

In January 2009, the Financial Services Authority (FSA) took its first anti-bribery enforcement action by fining insurance broker AON £5.25m. The FSA’s fine came on the back of a finding that AON had failed to establish and maintain effective systems and controls to counter bribery and corruption risks, in breach of principle three of the FSA’s Principles of Business.

Although modest in size when compared to the record $800m (£568m) which Siemens agreed to pay to the US Department of Justice and Securities and Exchange Commission (SEC) in December 2008, this is nevertheless a watershed in the UK’s fight against bribery. Had AON not received a 30% discount for early settlement, the fine would have considerably exceeded the amount AON received as a result of the suspicious payments.

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