FCA fines and bans Martin Sarl for dishonest and reckless conduct 

Between 7 November 2017 and 24 October 2019, Mr Sarl, who was the sole director at Perry Prowse (Insurance Consultants) Ltd, failed to pass clients’ premiums to insurers, meaning that some customers were left uninsured without their knowledge.  

The FCA's investigation uncovered that Mr Sarl used money from the firm’s client account to pay both his personal debt, and that of the firm. That was not allowed under the FCA’s Client Money rules, and these funds should have been kept separate. 

As a result, there was not enough money to transfer the premiums - that his customers had paid to him - to insurers, leaving customers without cover and at risk of having their home, and car insurance claims rejected. 

When he was asked questions by customers about their insurance, Mr Sarl hid the truth, even going as far as blaming a false 'IT glitch'. In at least one instance, a customer had a claim rejected because they did not have cover in place. 

Therese Chambers, Joint head of Enforcement and Market oversight at the FCA said:

'Mr Sarl's customers trusted him to keep their money safe and to secure the insurance cover they needed. Instead he helped himself to prop up his business and personal finances. He compounded this by lying to his customers.

'This left many people at risk of being unable to make a claim should they have needed to. It is right that Mr Sarl should be banned from the industry'. 

Notes to editors

1. Final Notice 2024: Martin Christopher Sarl (PDF)[1]
2. The FCA has imposed a financial penalty on Mr Sarl for £5,021 for his failure to comply with Statement of Principle 1 pursuant to section 66 of the Act. Mr Sarl’s penalty was reduced from £63,600 as Mr Sarl provided evidence that the payment of £63,600 would cause him serious financial hardship. The penalty was reduced to £5,021 as this is the amount that Authority considers was the financial benefit derived directly from his breaches and it would not be appropriate to allow him to retain this benefit.
3. As a result of the actions of Mr Sarl, the FCA finds that he is not a fit and proper person to perform any function in relation to any regulated activities carried on by any authorised or exempt person or exempt professional firm, and the FCA withdraws the approval for Mr Sarl to perform the function of SMF3 Executive Director at Perry Prowse.
4. On 13 September 2019, the FCA took action to vary Perry Prowse’s permission to remove all of its regulated activities with immediate effect. On 15 January 2020, the firm entered into liquidation. 
5. The customer whose insurance claim was refused because they did not have insurance in place was later reimbursed through the Financial Services Compensation Scheme.
6. The Client Money Rules require firms to calculate the amount of client money that should be segregated in a separate client bank account. Firms must segregate the client money until the premium is either paid to the insurer or client money is paid out to a client. 
7. Firms must always hold the right amount of client money in a segregated client bank account to avoid a shortfall occurring. The FCA continues to take failures to segregate appropriately seriously as this action shows.
8. Find out more information about the FCA[2].