Lloyd's Managing Agents faced with four separate anti-bribery reporting obligations
The recent Lloyd's Market Bulletin on the Bribery Act is an excellent guide for Managing Agents, but it suggests that in the event of an incident of bribery (or even suspected bribery) the Managing Agents may need to make as many as four separate reports about their suspicions:
- First, to the SFO as the lead investigator of bribery and corruption. The SFO actively encourages self-reporting of bribery;
- Secondly, to the Serious Organised Crime Agency (SOCA) - it should not be forgotten that bribery creates proceeds of crime, giving rise to money laundering issues;
- Thirdly, to the FSA - an incident of bribery could suggest poor or inadequate anti-financial crime systems and controls;
- And finally, if reports are made to both SOCA and FSA, Lloyd's must be informed.
Of course, it goes without saying that such reports should be carefully managed. For a sector less under attack from money launderers than the banks, this level of reporting may come as a surprise, and may appear a disproportionate regulatory burden.