Settlements

ST-48
Aon Corporation / Aon Limited
Aon Corporation
United Kingdom
Financial Services Authority
[payments to third parties in Bahrain, Bangladesh, Bulgaria, Burma, Indonesia, and Vietnam]
2009
1/6
Unknown
Legal Person
Civil
Final Notice (of Penalty)
Civil Penalty
$7,632,400.00
$0
$0
$7,632,400
$0
Art.16, Art.26
Art. 1, Art. 2, Art. 8
Financial Services Authority Principle 3 (reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems)
Financial Services Authority Principle 3 (reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems)
Yes
According to the UK Financial Services Authority's Final Notice of January 6, 2009 to Aon Limited, the FSA issued the penalty of GBP 5.25 million (US $7,864,970) in respect to Aon Limited's breach of Principle 3 of the FSA's Principles for Businesses which occurred between January 2005 and September 2007. The Final Notice stated that the company qualified for a 30% discount under the FSA's settlement discount scheme and that without the discount the fine would have been GBP 7.5 million. As a result of the systems and controls failings at Aon Limited, this gave rise to unacceptable risk that Aon Ltd could become involved in potentially corrupt payments to win or retain busines. During the relevant period, 66 suspicious payments amounting to US$2.5 million and EUR 3.4 million were paid to nine "Overseas Third Parties" (and a number of other suspicious payments to those Overseas Third Parties were made prior to the 2005, before Aon became regulated by the FSA). The Final Oder stated that as a result of the suspicious payments, business that may have been secured or retained amounted to approximately US $7.2 million and EUR 1 million. An Explanatory Note of February 27, 2009 to the Final Order noted that while certain payments were made through Aon's Bahraini business (Aon Re Middle East WLL) during the Relevant Period, the Final Notice relates solely to Aon Ltd in the UK and the FSA's investigation did not identify any payments made to Bahraini individuals or companies. (Source: UK Financial Services Authority, Final Notice of January 6, 2009 to AON Limited and "Explanatory Note to the Final Notice for Aon Limited dated 6 January 2009," February 27, 2009, accessed at http://www.fsa.gov.uk/pubs/final/aon.pdf and UK Financial Services Authority Press Release, "FSA fines AON Limited [GBP] 5.25m for failings in its anti-bribery and corruption systems and controls," FSA/PN/004/2009, January 8, 2009, accessed at http://www.fsa.gov.uk/pages/Library/Communication/PR/2009/004.shtml.)