Aon Corporation, a publicly-traded insurance brokerage firm headquartered in Chicago, has entered into a non-prosecution agreement with the Department of Justice and agreed to pay a $1.76 million penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA).  Aon also reached a settlement with the SEC and agreed to pay approximately $14.5 million in disgorgement and prejudgment interest.   Aon’s United Kingdom subsidiary, Aon Limited, administered certain training and education funds in connection with its reinsurance businesses. The SEC complaint alleges that Aon 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 several countries. Funds were used to reimburse officials for non-training related activity, including travel with spouses to overseas tourist destinations, or for uses that could not be determined from Aon’s books and records and which did not include any recorded business purpose.  The Compendium summary and government documents may be accessed here.