The FCA and Bluefin

The FCA has issued a Final Notice for Bluefin Insurance Services Limited, imposing a penalty of £4,023,800.

The final notice can be seen here: https://www.fca.org.uk/news/press-releases/fca-fines-bluefin-4m-misleading-customers

The FCA found that the firm breached Principle 3 (Management and Control) and Principle 7 (Communications with Clients).

In the period in question, (9 March 2011 and 31 December 2014) Bluefin was owned by AXA, and in that period, the FCA found that Bluefin had failed to implement adequate systems and controls to manage the conflict that arose from this ownership.

The FCA found that the firm’s culture promoted business strategies above treating customers fairly. That strategy, being focused on increasing the volume of business placed with its sole shareholder, AXA.

Bluefin customers were not informed of this policy and so risked being misled into believing that they were dealing with a broker who would conduct an unbiased search of the marketplace.

The final notice is clear that no criticism is made of any other member of the AXA group besides Bluefin.

ICOBS rules state that a firm must declare if an insurer owns more than 10% of its shares (this will be amended to 10% or more under the IDD) or if the firm owns shares in an insurer which follow the same limits and have appropriate conflicts of interest policies to manage such conflicts arising out of the shareholding.

If any of our readers are in a position where the shareholding limits apply, they should be considering this action urgently, review how they disclose the fact to their customers, and ensure that they have robust conflicts management procedures in place to deal with any such issues.

Please speak to your usual RWA Regional Business Manager if you have any questions or need any assistance.

About the author

Terence is the Compliance Director at RWA. He has over 35 years' experience in the Financial Services environment, covering general insurance, investments and mortgages. Before joining RWA, Terence worked for a large PLC insurance brokerage in Manchester, overseeing some 20 acquisitions. He was made a Director of RWA in 2011 and has worked with insurance broking firms of all sizes across the UK. He has a particular interest in Financial Crime and the protecting the insurance broker. Terence is also Executive Chairman of the Association of Professional Compliance Consultants (APCC), the professional body for the compliance consultancy sector.

Terence Clark

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