Mazars were instructed in 2021 by a UK insurer to investigate the relationship with and the circumstances surrounding one of their lead providers to which large marketing payments were being made in a loss-making arrangement.
The investigation focused on the origination of the relationship and the due diligence that was performed ahead of the arrangement, and examined the conduct of members of senior management throughout, in their execution and fulfilment of their responsibilities under the Financial Conduct Authority’s (“FCA”) Senior Management and Certification Regime (“SMCR”).
The investigation involved over 20 interviews and a comprehensive study of the organisation’s policies and procedures relating to onboarding and dealing with intermediaries. There was also a full review of 300,000+ emails from the inboxes of key custodians throughout the period in which the organisation traded with the lead provider. Our findings were presented in a report to the board, which was subsequently shared with the FCA and the Prudential Regulation Authority and led to the dismissal of a number of employees within the organisation.
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