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The Securities and Exchange 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.
Without admitting or denying the allegations in the Commission's complaint,
Aon consented to the entry of a final judgment permanently enjoining it from
future violations of Sections 13(b)(2)(
) and 13(b)(2)(
B) of the Exchange
Act and ordering the company to pay disgorgement of $11,416,814 in profits,
together with prejudgment interest thereon of $3,128,206, for a total of
$14,545,020. Aon's proposed settlement offer has been submitted to the court
for its consideration. In a related criminal proceeding, DOJ announced today
that Aon has entered into a non-prosecution agreement under which the
company will pay a $1.764 million criminal fine for the misconduct. Aon
cooperated with the Commission's and DOJ's investigations and implemented
remedial measures during the course of the investigations.
The Commission acknowledges the assistance of the Fraud Section of DOJ's
Criminal Division, the Federal Bureau of Investigation, and the Financial
Services Authority of the U.K. in this matter.
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