Tysers Insurance Brokers Limited (formerly known as Integro Insurance Brokers Limited) was an international reinsurance broker based in the United Kingdom. It was acquired by AUB Group Limited, an Australian group of retail & wholesale insurance brokers and underwriting agencies, in September 2022.
H.W. Wood Limited was an international reinsurance broker based in the United Kingdom.
According to the documents in this case, between 2013 and 2017, Tysers and H.W. Wood engaged in a conspiracy in which their employees and third-party agents agreed to pay bribes totaling approximately $2.8 million to the then-chairman of two Ecuadorian state-owned insurance companies, Seguros Sucre S.A. and Seguros Rocafuerte S.A., as well as three other Ecuadorian officials in order to obtain reinsurance business with the state-owned insurance companies. In furtherance of the scheme, Tysers paid approximately $20.3 million in commissions and H.W. Wood paid approximately $7.9 million in commissions and premium payments to the intermediary company that paid the bribes. Tysers retained commissions of approximately $10.5 million and H.W. Wood retained commissions of approximately $2.3 million.
On October 24, 2023, the DOJ filed a single count information in the Southern District of Florida against Tysers and H.W. Wood alleging a conspiracy to violate the anti-bribery provisions of the FCPA. On November 20, 2023, both companies entered into separate deferred prosecution agreements with the DOJ, each with a term of three years.
Under the terms of the DPA with Tysers, the company agreed to pay a criminal fine of $36,000,000 and to forfeit $10,589,275 and to self-report on the status of the company's anti-corruption compliance for a term of three years. The fine represented a 25 percent reduction off the bottom of the sentencing guidelines range. AUB Group also agreed to the compliance provisions of Tysers DPA.
Under the terms of the DPA with H.W. Wood, the company agreed to pay a criminal fine of $508,000 and to self-report on the status of the company's anti-corruption compliance for a term of three years. Though the DOJ determined that H.W. Wood should pay a criminal fine of $22,500,000 and to forfeit $2,338,735, the fine and forfeiture were reduced due to the company's inability to pay. The $22,500,000 fine represented a 25 percent reduction off the bottom of the sentencing guidelines range.
The DOJ noted both Tysers and H.W. Wood's cooperation and remediation.
