This was due to his failing to implement proper systems and controls to ensure customers' money held by the firm was adequately protected
BBNIB was authorised as a general insurance broker between 14 January 2005 and 8 May 2006. During that period Harrison was chief executive and responsible for ensuring that BBNIB complied with the FSA's client money rules. He failed to do so.
In July 2005, BBNIB's auditors identified serious failings in its client money systems and practices which meant that the firm was unable to ensure compliance with the FSA's client money rules. Prior to receiving this information from the firm's auditors Harrison had neither known nor enquired whether BBNIB was complying with those rules.
Margaret Cole, FSA director of enforcement, said: "Mr Harrison was an Approved Person who failed to carry out his controlled functions, which included chief executive of his firm, with due skill, care and diligence. His failure meant that BBNIB did not provide adequate protection for its clients' money. The client money rules are designed to ensure that money belonging to customers is protected and those responsible for firms which hold client money should appreciate that they are responsible for ensuring that the rules are complied with."
Harrison was responsible for the firm's failure to segregate client money, to keep track of client money held by third parties and to perform essential client money calculations and reconciliations. As a result of these failings client money was not adequately protected and only after extensive investigation by audit professionals were accurate balances struck and confirmation given that they were genuinely in credit.
Harrison has accepted personal responsibility for the failings at BBNIB and the FSA has given him full credit for his conduct following the identification of this issue. Otherwise a more severe sanction might have been imposed.
BBNIB is no longer a trading company following the sale of its business assets earlier this year.