Marsh & McLennan Companies, Inc. ("Marsh") is a global professional services firm in the areas of risk, strategy and people. The Company conducts business through two segments: Risk and Insurance Services, which includes risk management activities as well as insurance and reinsurance broking and services; and Consulting, which includes health, wealth and career services and products, and specialized management, economic and brand consulting services. On April 1, 2019, Marsh acquired all of the outstanding shares of Jardine Lloyd Thompson Group plc ("JLT"), an insurance company based in England.
In its 10-Q filed on may 1, 2020, Marsh disclosed that in 2017, JLT had identified payments to a third-party introducer that had been directed to unapproved bank accounts. These payments related to reinsurance placements made on behalf of an Ecuadorian state-owned insurer between 2014 and 2017. JLT voluntarily reported the matter to unspecified law enforcement authorities in early 2018, and Marsh indicated that it and JLT were cooperating with the authorities.
In February and March 2020, money laundering charges were filed in the United States against a former employee of JLT, the principals of the third-party introducer, and a former official of the state-owned insurer. These individuals, including the former JLT employee, have since pleaded guilty to criminal charges.
In its 10-K filed on February 16, 2022, Marsh disclosed that the DOJ had notified notified JLT in December 2021 of its intention to decline to pursue any charges against any JLT entity and to seek disgorgement of $29 million in alleged gross profits on this account. JLT has agreed in principle to this resolution, and Marsh accrued the amount in the fourth quarter 2021.
On March 18, 2022, the DOJ issed a declination letter pursuant to the agency's FCPA Corporate Enforcement Policy to JLT. Under the terms of the declination, JLT agreed to disgorge $29,081,951.
