Aon Securities Llc

Allegations: 1) FROM 1983 TO 2007, SUBSIDIARIES OF AON CORPORATION IN A NUMBER OF COUNTRIES MADE IMPROPER PAYMENTS TO VARIOUS PARTIES AS A MEANS OF OBTAINING INSURANCE BUSINESS IN THOSE COUNTRIES. 2) THESE PAYMENTS WERE NOT ACCURATELY REFLECTED IN AON'S BOOKS AND RECORDS. 3) AON FAILED TO MAINTAIN AN ADEQUATE INTERNAL CONTROL SYSTEM REASONABLY DESIGNED TO DETECT AND PREVENT THESE PAYMENTS. 4) THESE ACTS VIOLATE SECTIONS 13(B)(2)(A) AND 13(B)(2)(B) OF THE SECURITIES EXCHANGE ACT OF 1934. Status: Final Summary: BEGINNING IN 2007, AON CORPORATION REPORTED IN ITS FILINGS WITH THE SEC THAT FOLLOWING INQUIRIES FROM REGULATORS, IT HAD COMMENCED AN INTERNAL REVIEW OF ITS COMPLIANCE WITH CERTAIN U.S. AND NON-U.S. ANTI-CORRUPTION LAWS, INCLUDING THE U.S. FOREIGN CORRUPT PRACTICES ACT ("FCPA"). AN OUTSIDE LAW FIRM WITH SIGNIFICANT EXPERIENCE IN THE AREA OVERSAW THE REVIEW. ON DECEMBER 20, 2011, AON ANNOUNCED THAT IT HAD AGREED TO FINALIZE THESE MATTERS BY PAYING APPROXIMATELY $14.55 MILLION TO THE U.S. SECURITIES & EXCHANGE COMMISSION ("SEC") IN DISGORGEMENT AND INTEREST TO SETTLE CIVIL ACTION RELATING TO CERTAIN PAYMENTS MADE IN OVERSEAS JURISDICTIONS BETWEEN 1983 AND 2007. SINCE BEGINNING ITS INTERNAL REVIEW OF THESE ISSUES IN 2007, AON HAS PUT IN PLACE A COMPREHENSIVE, GLOBAL AND ROBUST ANTI-CORRUPTION PROGRAM DESIGNED TO PREVENT AND DETECT IMPROPER CONDUCT. THROUGHOUT THE COURSE OF ITS REVIEW, AON COOPERATED FULLY WITH ALL RELEVANT AGENCIES.