Aon Corporation
Aon Corporation
United States
Securities and Exchange Commission
Costa Rica, Egypt, Vietnam, Indonesia, United Arab Emirates, Myanmar, Bangladesh and other unspecified countries
United Kingdom
Legal Person
Consent to Permanent Injunction
Disgorgement of Profits, Prejudgment Interest
Art.16, Art.26
Art. 1, Art. 2, Art. 8
Falsification of books and records, Internal controls violations
No admission or denial of alleged offenses
According to the Securities and Exchange Commission Litigation Release, on December 20, 2011, the Commission "today filed a settled enforcement action in the U.S. District Court for the District of Columbia against Aon Corporation (Aon), an Illinois-based global provider of risk management services, insurance and reinsurance brokerage, alleging violations of the books and records and internal controls provisions of the Foreign Corrupt Practices Act (FCPA). Aon will pay a total of approximately $14.5 million in disgorgement and prejudgment interest to the SEC. In a related action, Aon will pay a $1.764 million criminal fine to the U.S. Department of Justice (DOJ). The Commission's complaint alleges that Aon's subsidiaries made over $3.6 million in improper payments to various parties between 1983 and 2007 as a means of obtaining or retaining insurance business in those countries. The complaint alleges that some of the improper payments were made directly or indirectly to foreign government officials who could award business directly to Aon subsidiaries, who were in position to influence others who could award business to Aon subsidiaries, or who could otherwise provide favorable business treatment for the company's interests. The complaint alleges that these payments were not accurately reflected in Aon's books and records, and that Aon failed to maintain an adequate internal control system reasonably designed to detect and prevent the improper payments. According to the Commission's complaint, the improper payments made by Aon's subsidiaries fall into two general categories: (i) training, travel, and entertainment provided to employees of foreign government-owned clients and third parties; and (ii) payments made to third-party facilitators. Aon subsidiaries made these payments in various countries around the world, including Costa Rica, Egypt, Vietnam, Indonesia, United Arab Emirates, Myanmar, and Bangladesh. The complaint alleges that Aon realized over $11.4 million in profits from these improper payments." The SEC Litigation Release acknowledged the assistance of the UK Financial Services Authority in this matter. (Source: US Securities and Exchange Commission, Litigation Release No. 22203 / December 20, 2011, Securities and Exchange Commission vs. Aon Corporation, Civil Action No. 1:11-cv-02256 (D.D.C.) (filed Dec. 20, 2011), "SEC Files Settled FCPA Charges against Aon Corporation.")