While many companies here in the US complain about the enforcement of the Foreign Corrupt Practices Act (FCPA), and are actively seeking to soften its enforcement by lobbying Congress to amend the FCPA, just imagine how they might feel about paying a multi-million dollar fine for a situation in which no bribery was proven. That is the situation that UK insurance broker Willis Ltd., found itself in yesterday, in what reporter Sam Rubenfeld termed “the largest fine by the FSA (the UK Financial Services Authority) … ever imposed for failure to implement controls to prevent financial crimes”. The FSA announced on July 21 that it had assessed a penalty of £6.9MM to the insurance broker Willis Ltd., for failing to ensure payments it made to third parties were not used for corrupt purposes.