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This week, the brokerage firm Besso Limited was fined a not insubstantial £315,000 by the Financial Conduct Authority (FCA).
So why was the fine imposed? Whatever did they get wrong?
Well, according to the FCA:
Besso failed to take reasonable care to establish and maintain effective systems and controls for countering the risks of bribery and corruption associated with making payments to parties who entered into commission sharing agreements with Besso or assisted Besso in winning and retaining business.
In particular, although Besso had introduced written bribery and corruption policies and procedures in November 2009, the FCA considered that they were:
not adequate in their content or implementation.
This case is a wake-up call to businesses who think that they can put compliance with the Bribery Act 2010 onto the back burner. The Act is something that should concern all UK businesses—and indeed any non-UK businesses which have business interests in the UK.
Whilst the FCA only regulates certain businesses in the UK, such as financial services firms, it is clear that the Serious Fraud Office (which prosecutes bribery and corruption offences) is champing at the bit to get its teeth into a few juicy prosecutions.
So here's 10 tips to remind your business how to deal with bribery and corruption matters and to ensure compliance with the 2010 Act:
So that’s that. Ten tips already.
So over to you: do you have any thoughts? Have you implemented an anti-bribery policy? If so, what challenges did you encounter? Let us know!
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