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Aon Limited Confirms Settlement of £5.25m with FSA


Fine relates to systems and controls failings regarding payments made to overseas third parties
FSA recognises that pro-active determination of Aon Limited’s current senior management to improve systems and controls in this area is a “model of best practice that other firms may wish to adopt”

LONDON.- Aon Limited today confirms it has agreed to a £5.25 million settlement with the UK Financial Services Authority (FSA) regarding failings that occurred in its risk management systems relating to its dealings with non-FSA-authorised overseas third parties between 14 January 2005 and 30 September 2007. These failings arose principally out of its aviation and energy sectors, in relation to business in certain non-UK, high-risk jurisdictions.

Aon Limited recognises that certain failings in its systems and controls have occurred in the past and that this has led to a number of potentially inappropriate payments being made to third parties in certain non-UK high-risk jurisdictions. The FSA has made it clear that Aon Limited’s conduct was neither deliberate nor reckless. Since becoming aware of these issues, Aon Limited and its current senior management have been determined to remedy their relevant systems and controls to guard against such problems happening again in the future.

Aon Limited shares the FSA’s interest in creating an environment of integrity within the industry. As stated by the FSA in its press release:

“Aon Ltd and its current senior management have demonstrated that they treat this matter with the utmost seriousness. The FSA considers that the pro-active determination of Aon Ltd’s current senior management to identify past issues and improve the firm’s systems and controls in this area is a model of best practice that other firms may wish to adopt.”

Working with the FSA and other regulatory authorities, Aon has significantly strengthened and enhanced its controls around the usage of third parties, including:

· implementation of a robust global anti-corruption compliance programme

· risk-based procedures to review all existing and proposed third party relationships

· a globally implemented third party policy controlling and restricting the use of overseas third parties, particularly those in high-risk jurisdictions

These enhancements are related to Aon Corporation’s disclosure in its public filings in November 2007 that the firm is carrying out an internal review of its compliance with certain US and non-US anti-corruption laws, including the US Foreign Corrupt Practices Act. Aon is cooperating with all relevant agencies, including the US Securities and Exchange Commission and US Department of Justice, and the FSA.

Peter Harmer, CEO of Aon Limited, said: “We recognise and regret the failings that occurred in our systems and controls for payments to third parties and are pleased that our efforts to remedy and enhance our controls are considered by the FSA to be ’a model of best practice that other firms may wish to adopt’.”


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