Willis Limited

Activities and protection

What they can do, and how you are protected

• Hold or safeguard your money · Manage or trade investments FSCS may apply
  Eligible investment and pension claims are typically FSCS-protected up to £85,000 per person, depending on the product and your circumstances.
• Give regulated advice FSCS may apply
  A claim for unsuitable advice is itself FSCS-protected, up to the limit that applies to the product you were advised on.
• Sell or arrange insurance FSCS may apply
  Eligible insurance claims may be FSCS-protected, often 90%, or 100% for compulsory or long-term cover.
• Lend or arrange credit No FSCS cover
  Consumer credit is not covered by the FSCS, so there is no compensation scheme if the firm fails.

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Complaints: You can refer a complaint about this firm to the Financial Ombudsman Service for free, whichever activity it relates to.

Track record

Action taken against them

1 fine in 2011, £6.89m in total. This is part of the official register record and is worth reviewing before going ahead.

• Fined £6.89m on 21 July 2011

  On 21 July 2011, the FSA imposed a financial penalty of £6,895,000 on Willis Limited for breaches of Principle 3 of the FSA's Principles for Businesses and SYSC 3.2.6 R of the FSA's Senior Management Arrangements, Systems and Controls Handbook which occurred between 14 January 2005 and 31 December 2009. The breaches related to the actions taken by Willis Limited to counter the risks of bribery and corruption associated with making payments to non-FSA authorised overseas third parties (Overseas Third Parties) who assisted Willis Limited in winning business from overseas clients, particularly in high risk jurisdictions. Willis Limited agreed to settle at an early stage of the FSA's investigation. It therefore qualifies for a 30%(Stage 1) discount under the FSA's executive settlement procedures. Were it not for this discount, the FSA would have proposed the imposition of a financial penalty of £9,850,000 on Willis Limited. Willis Limited did not take reasonable care to establish and maintain effective systems and controls for countering the risks of bribery and corruption associated with making payments to Overseas Third Parties who helped Willis Limited win and retain business from overseas clients. In particular between January 2005 and August 2008: (1) Willis Limited failed to ensure that it established and recorded an adequate commercial rationale to support its payments to Overseas Third Parties. An adequate business case would have demonstrated in each case why it was necessary for Willis Limited to use an Overseas Third Party to win business and what services Willis Limited would receive from that Overseas Third Party in return for a share of its commission. Willis Limited's policies did not provide any written guidance on the amount of detail required when recording why it was necessary to use an Overseas Third Party. No formal training was provided to staff in this matter who only recorded a very brief description of the reasons for the commission payment and what services Willis Limited would receive in return. The FSA's investigation found for nearly all of the Overseas Third Parties based in high risk jurisdictions who introduced business to Willis Limited between January 2005 and August 2008, Willis Limited's reason for sharing commission was inadequately recorded. Without adequate documentation, Willis Limited could not adequately monitor the effectiveness of its procedures. (2) Willis Limited did not ensure that adequate due diligence was carried out on Overseas Third Parties to evaluate the risk involved in doing business with them. Such due diligence would have, for example, enabled Willis Limited to assess whether the Overseas Third Party was connected with the insured, the insurer or public officials. These are significant factors in assessing the risk that Overseas Third Parties might in turn make improper payments to help Willis Limited win or retain business from overseas clients. Although some due diligence was carried out on Overseas Third Parties based in high risk jurisdictions who introduced business to Willis Limited between January 2005 and August 2008, we found that in nearly all cases Willis Limited did not carry out enough due diligence to address the risk that the Overseas Third Parties may have been connected to the insured, the insurer or public officials. (3) Whilst Willis Limited did review the reason for sharing commission regularly, it failed to review in sufficient detail its relationships with Overseas Third Parties on a regular basis to confirm that it was still necessary and appropriate for Willis Limited to continue with the relationship. (4) Willis Limited did not adequately monitor its staff to ensure that each time it engaged an Overseas Third Party an adequate commercial rationale had been recorded and that sufficient due diligence had been carried out. These failures contributed to a weak control environment surrounding the making of payments toverseas Third Parties. This gave rise to an unacceptable risk that payments made by Willis Limited to Overseas Third Parties could be used for corrupt purposes, including paying bribes to persons connected with the insured, the insurer or public officials. In August 2008, Willis Limited introduced improved policies and guidance which were aimed at mitigating its bribery and corruption risks. However, Willis Limited failed to ensure those policies were adequately implemented. Willis Limited staff continued in a substantial number of cases to fail to carry out sufficient due diligence to support its payments to Overseas Third Parties. Although in late 2008 it reviewed how its new policies were operating in practice (which resulted in revised guidance being introduced in May 2009), Willis Limited should have taken additional steps between August 2008 and May 2009 to ensure that its improved policies were adequately implemented by staff and that failures by staff to adhere to the new policies were identified in a timely manner. The Willis Limited Board was involved from 2007 in the development of these new anti-bribery and corruption policies. However, the Board did not receive sufficient relevant management information regarding the performance of these new policies which would have allowed them to assess whether bribery and corruption risks were being mitigated effectively. The FSA considers these failings to be serious because: (1) The involvement of UK financial institutions in corrupt or potentially corrupt practices overseas undermines the integrity of the UK financial services sector. Unless they have in place robust systems and controls which govern the circumstances in which payments may be made to third parties and then ensure those systems and controls are followed, UK financial services firms risk contravening UK and/or overseas anti-bribery laws. The FSA's financial crime and market confidence statutory objectives are both endangered by UK firms' failures in this regard. (2) Willis Limited is one of the largest insurance and reinsurance brokerage and risk management firms in the UK. As such, it has a leading competitive position in the market and the firm's practices set an example which is seen by other market practitioners and customers. (3) The failings identified principally existed in two of Willis Limited's major business units for a significant period. (4) The failings in both Willis Limited's policies and the implementation of those policies, increased the risk that a payment made to an Overseas Third Party could be used for corrupt purposes. During our investigation, Willis Limited identified as suspicious a number of payments which it had made to two Overseas Third Parties in respect of business carried out in Egypt and Russia during the Relevant Period. It reported these matters to the Serious Organised Crime Agency (SOCA). These payments totalled approximately US $227,000. The first suspicious activity report (SAR) arose as part of Willis' detailed review of Overseas Third Parties following the commencement of our investigation. The other SAR arose as a result of a generally increased focus on bribery and corruptions risks both within Willis and the industry more generally, including the FSA's thematic review of this area. (5) The revenue earned by Willis Limited relating to these breaches is significant. Over the course of the Relevant Period, the gross commission earned by Willis Limited from business introduced by Overseas Third Parties based in high risk jurisdictions amounted to approximately £59.7 million. Of this, Willis Limited paid approximately £27 million in commission to these Overseas Third Parties. The payments made to these Overseas Third Parties therefore accounted for around 45% of the brokerage earned. The FSA did not seek to determine as part of its investigation whether any of this business was corrupt. The net commission earned by Wils Limited relating to Overseas Third Parties in high risk jurisdictions during the Relevant Period represented approximately 1% of Willis Limited's total net revenue during this period. (6) The FSA did not find evidence to suggest that Willis Limited's conduct was either deliberate or reckless. Nonetheless, as Willis Limited was aware of the bribery and corruption risks associated with making payments to Overseas Third Parties to obtain or retain business, particularly in high risk jurisdictions, it should have taken additional steps to monitor the adequacy of its procedures once implemented between January 2005 and May 2009. (7) In November 2007, the FSA sent a 'Dear CEO' letter to all wholesale insurance broker firms, including Willis Limited. This letter affirmed the FSA's expectations in relation to payments to third parties and expected firms to review their business practices to ensure that they were not involved in, or associated with, illicit payments. Willis Group had already by this time begun to review its existing policies in respect of payments to Overseas Third Parties and develop new policies to mitigate the associated bribery and corruption risks which were later introduced in August 2008. In January 2009, the FSA fined Aon Limited for breaching Principle 3 of the FSA's Principles for Businesses for failing to take reasonable care to establish and maintain effective systems and controls to counter the risks of bribery and corruption associated with making payments to overseas firms and individuals who assisted Aon in winning or retaining business. By this time, Willis had taken some steps to review the effectiveness of the policy introduced in August 2008. However, notwithstanding the 'Dear CEO' letter and the Aon fine, there continued to be failings in Willis Limited's implementation of these policies as described above up until May 2009. Willis Limited's failings therefore merit the imposition of a significant financial penalty. In deciding the size of the penalty, the FSA recognises that the following circumstances serve to mitigate the seriousness of Willis Limited's failings:: (1) Willis Limited had sought to mitigate the risks of bribery and corruption in its business activities from 2007. A Group wide review was initiated by Willis Group's office of General Counsel in April 2007. Willis Limited introduced new policies and procedures as a result of this review in August 2008. Willis Limited reviewed its policies shortly after this, having monitored the implementation of the August 2008 policy and given consideration to the guidance given in the Aon decision in January 2009. As a result, further guidance was issued in May 2009. Willis Limited's proactive efforts thereby resulted in an improved control environment. (2) Since May 2009 and following the end of the Relevant Period, Willis Limited has taken steps to address the failings identified in this notice. This includes the introduction of new and enhanced systems and controls in relation to anti-bribery and corruption, restructuring the financial arrangements in relation to business unit compliance officers in order to strengthen the independence of the compliance function and improving systems relating to documentation which will facilitate the production of relevant management information. (3) Willis has, where appropriate, taken disciplinary action in relation to staff who it alleges have been involved in the making of potentially inappropriate payments or who failed to comply with Willis' policy. (4) Willis is committed to carrying out a comprehensive and robust risk based review of past payments made to Overseas Third Parties in order to satisfy itself and demonstrate to the FSA that it has identified any potentially inappropriate payments to Overseas Third Parties made during the Relevant Period. (5) In carrying out these steps, Willis Limited has to date incurred significant costs both in financial temsand in management time expended. (6) Since the commencement of the FSA's investigation in August 2010, Willis Limited, Willis Group and both their current senior management have cooperated with the FSA's investigation.

Common questions

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