FCPA Scorecard Blog

AON Corporation today settled a Foreign Corrupt Practices Act matter with the US Department of Justice and US Securities and Exchange Commission for a combined monetary sanction of $16.264 million.  This action follows the 2009 fine of £5.25 million issued by the United Kingdom's Financial Services Authority. AON resolved the DOJ matter with a non-prosecution agreement, in which the company admitted to certain FCPA books and records violations related to interactions with officials of Costa Rica's state-owned insurance company. AON neither admitted nor denied conduct identified in the SEC Litigation Release, which identified conduct in Costa Rica, Egypt, Vietnam, Indonesia, United Arab Emirates, Myanmar, and Bangladesh.  The Release states that "AON realized over $11.4 million in profits from these improper payments." If you have any questions about this FCPA Update, please contact Jamie Parkinson.