H.W. Wood Limited: The Intermediary That Had to Stay Invisible

In the H.W. Wood Limited FCPA case, the British broker admitted using reinsurance commissions and premiums to fund bribes for Ecuadorian officials. Its criminal deferred prosecution agreement, filed in November 2023, describes an intermediary that helped win the business, handled the money and had to stay hidden from the insurers. If you worked on the placements, commission splits or payment approvals, the admissions describe decisions you may recognize from an ordinary business file.

H.W. Wood admitted that, from around 2013 through around 2017, employees and agents conspired to bribe officials to obtain and retain business from Seguros Sucre and Seguros Rocafuerte, both state-owned Ecuadorian insurers. The intermediary introduced H.W. Wood and fellow British broker Tysers, then operating as Integro Insurance Brokers Limited, to the insurers’ chairman and other officials. The business depended on access to people who could direct public reinsurance accounts.

Reinsurance Premiums Became Bribe Money

Reinsurance transfers some or all of an insurer’s risk of paying claims to another insurance company. As H.W. Wood’s admitted statement of facts explains, a reinsurance broker arranges that transfer, collects the premium owed to the reinsurer and typically keeps part of the premium as its commission. That puts the broker inside the flow of money buying the coverage.

H.W. Wood approved the intermediary in two roles. As a producing agent, it helped bring in Ecuadorian public reinsurance business and received a share of the commissions. As a placing broker, it received premiums from H.W. Wood and was supposed to pass them to reinsurers after retaining its own commission. H.W. Wood controlled its commission splits and business decisions involving the intermediary and remained responsible to the insurer and insured client.

The company admitted that the intermediary sometimes passed as little as 25 percent of the premiums it received to reinsurers. It used the money it retained, among other things, to bribe officials at the state-owned insurers.

H.W. Wood’s agreement says it paid approximately $7.9 million in commissions and premiums to the intermediary while retaining approximately $2.3 million in commissions. Across the shared scheme, the intermediary paid at least approximately $2.8 million in bribes for the benefit of H.W. Wood, Tysers and itself. The money moved through accounts in Florida, Panama and Switzerland, including accounts held by other people for the officials’ benefit.

The Intermediary the Insurers Were Not Supposed to See

H.W. Wood admitted that its broker and others at the company knew Ecuador had prohibited local brokers and intermediaries in this business because of corruption concerns. The company used the intermediary anyway. The emails in its agreement show how the people arranging the business kept that relationship out of the insurers’ view.

The intermediary’s general manager supplied wording for an introductory letter to the insurers’ new chairman. He told H.W. Wood’s broker to blind copy the intermediary’s president and general manager, explaining:

Later messages told the broker to consult the intermediary before communicating with the insurers and to leave it out of documents submitted to Seguros Sucre. H.W. Wood’s broker agreed to the arrangement. When an insurer official outside the scheme asked about local contacts, the broker said a private law firm helped with paperwork, concealing the intermediary’s role.

The public-facing correspondence showed the British broker dealing with the insurer. The blind copies and private instructions showed the intermediary directing the conversation.

The Commission Breakdown Said Who Would Be Paid

H.W. Wood’s admitted emails show a commission negotiation turning into an explanation of the bribes. After the intermediary arranged a Rocafuerte policy for H.W. Wood and Tysers to co-broker, it demanded a larger share. It said failure to pay local people could cost the brokers both that account and future public business.

The H.W. Wood broker asked where the commission was going. The intermediary’s president replied that its proposed share included money for:

The broker forwarded the exchange to a Tysers division head for agreement. After conferring with him, the broker accepted the proposed split, including the allocation to those local people. In later correspondence, the H.W. Wood broker acknowledged that the intermediary had to look after third parties.

We see the absurdity in that exchange: asking where the money was going became a step toward approving the bribes. The intermediary put the political allocation in writing, and the broker agreed to pay it.

Compliance Asked for Receipts, the Broker Supplied Words

H.W. Wood’s agreement records a specific compliance inquiry into the intermediary’s expenses. During a renewal discussion in March 2015, the intermediary sought half the commission for expenses such as training and survey reports. H.W. Wood’s broker replied that the company had never been asked for surveys and that compliance wanted more information, including receipts.

The intermediary’s president responded with descriptions of inspections, valuations, training and acquisition costs they had discussed before. The broker then supplied language for the president to send back in a separate email. According to the broker’s message, H.W. Wood would confirm that wording and give the intermediary a larger portion of the commission.

Compliance asked for receipts. The broker supplied a script. We would want to hear from the employee who knew whether the training or survey work happened, as well as the employee who saw the request for receipts. The review of the intermediary matters at renewal just as much as when the relationship begins.

A 2022 Journal of Forensic and Investigative Accounting study of Fresenius Medical Care, Fresenius Medical Care: A Case Study on the FCPA, describes managers and employees continuing bribery despite flagged transactions and internal policies. In H.W. Wood’s admitted account, the next exchange supplied wording to obtain more commission.

From a Premium Payment to an Official’s Account

The admitted statement of facts follows particular premium payments into accounts benefiting officials. In January 2014, H.W. Wood transferred approximately $91,966 in premiums to the intermediary’s account in Panama. Five days later, the intermediary moved approximately $50,500 of those funds to its general manager’s account in Florida. That day, he transferred approximately $25,000 of those funds to an account held for the insurers’ chairman’s benefit.

The agreement also describes paperwork created to justify later bribes. The intermediary’s operator sent the chairman’s financial adviser a model contract describing purported investments in the chairman’s company. The adviser returned a signed contract, and payments reached a Swiss account held for the chairman’s benefit.

The premium trail identifies a recipient behind the intermediary’s account. The later investment contract shows a different way to disguise payments benefiting that same official. Connecting the outgoing payment to its eventual beneficiary lets an insider’s knowledge of the original transaction meet the bank records further down the chain.

H.W. Wood and Tysers Had Separate Agreements

The Justice Department charged H.W. Wood and Tysers together in a criminal information alleging a conspiracy to violate the Foreign Corrupt Practices Act. Each company entered its own deferred prosecution agreement and accepted responsibility for the conduct described in its own statement of facts.

In Tysers’ separate agreement, the company admitted paying approximately $20.3 million in commissions to the intermediary and retaining approximately $10.5 million. Its statement of facts also describes messages about shielding information from Seguros Sucre auditors.

What an Insurance Insider Can Recognize

The recurring pattern connects a public customer’s decision, an intermediary’s payment and the business explanation used to authorize it. In its 2025 letter declining prosecution of Liberty Mutual, the Justice Department reported evidence that the company’s Indian subsidiary bribed state-owned bank officials to obtain referrals to its insurance products. The letter says employees concealed payments through intermediaries and classified them as marketing expenses. For an insurance employee, the marketing label and the referral arrangement describe different sides of the same payment.

The pattern also appears beyond insurance. In the statement of facts accompanying its guilty plea, Gunvor admitted using intermediaries, fake consulting invoices and shell companies to conceal corrupt payments connected to Ecuadorian oil business. Its admitted account also says payments continued despite repeated failures to supply requested documentation or attend a compliance meeting.

At a reinsurance broker, you may know the placement, the premium received, the commission promised or the answer given when compliance questioned the expense. We connect that knowledge to the decisions and payments behind the paperwork. The H.W. Wood emails show why the explanation supplied inside the business can matter as much as the description on the bank transfer.

Your account of foreign bribery belongs with experts who can assess the available whistleblower programs and any separate fraud against the U.S. government. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

You Know What the Commission Was Buying

If you saw a hidden intermediary directing placements or a payment explanation being written to satisfy compliance, speak to one of our Whistleblower Experts about what the commission was really paying for. We build the case with you and bring in foreign-bribery whistleblower lawyers who understand broker commissions, diverted premiums and payments across borders. You bring the knowledge of the business, and we stay beside you as partners in pursuing the case.