On 17 April 2025, the UK’s Serious Fraud Office (SFO) announced it had charged United Insurance Brokers Limited (UIBL), a Lloyd’s-regulated insurance company, with the corporate offence of failing to prevent bribery under Section 7 of the Bribery Act 2010. The prosecution relates to alleged corrupt payments made by UIBL’s US-based intermediaries to Ecuadorian state officials between 2013 and 2016, in exchange for lucrative re-insurance contracts worth $38 million. This case represents a landmark moment in UK anti-bribery enforcement due to its international scope and high-value transactions, not to mention vital lessons for all companies.
The bribery allegations against UIBL
According to the SFO, UIBL received $6.2 million in commission for re-insurance services sold to Ecuador’s state insurers, covering utilities like water and electricity. Of that commission, $3.2 million was allegedly funnelled through intermediaries, some of which was used to bribe an Ecuadorian official to secure the business.
The charges fall under Section 7 of the UK Bribery Act 2010, which imposes strict liability on commercial organisations that fail to prevent bribery by persons associated with them, unless they can prove they had “adequate procedures” in place to prevent it. Representatives of UIBL are due to appear at Westminster Magistrates’ Court on 7 May.
This prosecution is significant. If it proceeds to a contested trial and is not resolved via a guilty plea or Deferred Prosecution Agreement (DPA), it will test the Section 7 “adequate procedures” defence before a jury which has not often been seen.
A toughening stance? Learning from Skansen and Sweett Group convictions
While this may be the first Section 7 jury trial led by the SFO, it is not the first such prosecution in the UK. Two earlier cases: Skansen Interiors Limited and Sweett Group plc offer important context and raise complex questions about the SFO’s evolving enforcement strategy.
Skansen Interiors Limited
In 2018, Skansen, a small office refurbishment company with just 30 employees, became the first company convicted under Section 7 of the Bribery Act. Its former managing director paid bribes totalling £10,000 to win office fit-out contracts worth £6 million. A larger bribe was later stopped by a new CEO, who implemented controls, reported the matter to authorities, and cooperated fully with investigators.
Despite this proactive stance, the jury found Skansen’s anti-bribery procedures insufficient. The court emphasised that the company had no formal anti-bribery policy and had failed to provide training to staff. Skansen was convicted, but as it was dormant and had no assets, it received an absolute discharge. No fine, no operational consequence, but the legal precedent was set.
Sweett Group
In contrast, Sweett Group plc, a construction consultancy firm, pleaded guilty in 2016 to failing to prevent bribes paid in the Middle East to secure a contract for a hotel project. This case was more straightforward. Sweett admitted wrongdoing, and the SFO did not pursue a trial. It was fined £2.25 million for failure to prevent bribery.
What made Sweett notable was that the conduct had initially been self-reported. However, unlike Skansen, the SFO concluded prosecution, as opposed to a DPA, was appropriate, reinforcing the message that self-reporting does not grant immunity.
Taken together, these cases show the complexities of Section 7 enforcement. Skansen sparked debate about proportionality and fairness. Sweett demonstrated that even larger companies with global operations could face convictions. And now, UIBL’s prosecution shows that international business transactions are firmly within the SFO’s sights.
What makes the UIBL bribery case different?
The UIBL case marks a shift in several ways and signals perhaps a renewed interest in prosecuting failure to prevent bribery cases.
International scope: The alleged bribery involves cross-border conduct and offshore intermediaries. This aligns with the SFO’s mandate to tackle complex, global financial crime.
High stakes: With $38 million in contracts and millions in commission at play, the financial scale dwarfs the figures in Skansen.
Jury trial anticipated: A jury hearing a failure-to-prevent bribery charge could potentially establish new interpretations of what is expected by “adequate procedures.”
Regulated sector: UIBL operates in the insurance industry and is part of the Lloyd’s market. This raises expectations around governance and compliance standards for regulated entities.
New leadership at the SFO: The agency, under Director Nick Ephgrave (a former assistant Met Police commissioner), may be signalling a more aggressive approach to international corporate corruption.
A serious legal test
If the UIBL case proceeds to trial, it will offer the clearest test yet of how UK courts assess the “adequate procedures” defence. It could also shape how companies view the risks of prosecution versus the benefits of self-reporting.
Critically, the case may answer a lingering question from Skansen: are smaller or cooperative companies disproportionately punished, while larger firms can negotiate DPAs? Or does the SFO now intend to bring more contested prosecutions, regardless of company size, to reinforce the Bribery Act’s teeth?
Implications for UK businesses
The SFO’s decision to bring charges against UIBL reinforces a stark message: UK companies must have effective, documented anti-bribery procedures in place—not just in policy, but in practice. Simply relying on good corporate culture or general ethics statements is not enough.
For companies operating internationally, especially in high-risk sectors or jurisdictions, the following must be priorities:
Clear anti-bribery policies that explicitly prohibit corruption.
Regular risk assessments tailored to geography, business relationships, and market conditions.
Due diligence on third-party agents, intermediaries, and partners.
Ongoing training for staff, particularly those working in business development or sales roles.
Strong reporting mechanisms and swift, decisive responses to red flags.
