The U.K. Serious Fraud Office (SFO) has charged United Insurance Brokers Limited (UIBL) with failing to prevent bribery by its associates in a case involving multimillion-dollar reinsurance contracts in Ecuador.
UIBL, a London-based reinsurance firm, is accused of allowing U.S.-based intermediaries to bribe Ecuadorean officials between October 2013 and March 2016 in exchange for awarding contracts valued at approximately $38 million. The contracts were issued by state-owned insurers covering Ecuador’s public sector infrastructure, including water and electricity companies.
According to the SFO, UIBL received $6.2 million in commissions for these services, with $3 million allegedly transferred to the intermediaries, who then used part of the funds to bribe an Ecuadorean official.
The charges were brought under Section 7 of the UK Bribery Act 2010, which makes it a criminal offence for a company to fail to prevent persons associated with it from engaging in bribery. If the case proceeds to trial, it will mark the first time the SFO brings a “failure to prevent bribery” case before a jury.
Nick Ephgrave QPM, Director of the SFO, stated:
“The SFO remains committed to stamping out international bribery wherever it may occur. British companies have a duty to prevent the harm caused by bribery when doing business at home and abroad, to ensure that the UK remains a safe and fair place to do business.”
Representatives of UIBL have been ordered to appear before Westminster Magistrates’ Court on Wednesday, 7 May 2025.
The case underscores the growing international reach of UK anti-bribery enforcement and the SFO’s use of corporate failure-to-prevent provisions in prosecuting global corruption. The British efforts are gaining prominence as Washington retreats from anticorruption enforcement.
In November 2023, the U.S. Department of Justice (DOJ) entered into deferred prosecution agreements with two other U.K.-based reinsurance brokers—Tysers Insurance Brokers Limited (formerly Integro) and H.W. Wood Limited—for related FCPA violations in Ecuador. The DOJ alleged that, between 2013 and 2017, the two companies conspired to pay $2.8 million in bribes to Ecuadorian officials to win business from Seguros Sucre S.A. and Seguros Rocafuerte S.A.
Tysers paid a $36 million penalty and forfeited $10.5 million in profits; H.W. Wood’s penalty was reduced to $508,000 based on its financial condition. Both firms were accused of routing payments through intermediaries operating in the U.S., Panama, and Ecuador to conceal illegal commissions, often disguising the payments as investments or service fees. Several individuals, including former Sucre chairman Juan Ribas, pleaded guilty in related U.S. proceedings.
The DOJ had previously declined to prosecute Jardine Lloyd Thompson (JLT) in 2022 for similar conduct, citing the company’s voluntary self-disclosure and cooperation. Another firm, Arthur J. Gallagher & Co., was cleared in 2023 after a DOJ inquiry was closed without action.
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