Last year ended with a bang on the FCPA front, with the announcement of two large settlements. The settlements took the U.S. government’s collection for FCPA penalties and disgorgement in 2011 over the half-billion dollar mark for the fourth year in a row. The settlements provide cautionary tales for business conduct and accounting. With the government on a sustained FCPA enforcement push, we expect to see more of the same in 2012.

On December 20, the SEC announced a $14 million settlement with Aon Corporation for failing to keep accurate books and records regarding payments to and for the benefit of foreign officials, and failing to devise and maintain adequate internal controls. Aon had to disgorge $11.4 million in what the SEC called “ill-gotten gains” (presumably the premiums on policies that Aon obtained or retained because of its payments) and prejudgment interest (of more than $3 million). The same day, the DOJ announced that Aon would pay a $1.76 million penalty to resolve FCPA violations stemming from payments in Costa Rica that also were a subject of the SEC action.