In December, 2011, the insurance giant Aon received a Non-Prosecution Agreement (NPA) from the Department of Justice (DOJ) in settling enforcement actions against it by the DOJ and Securities and Exchange Commission (SEC). Aon agreed to total fines and penalties in an amount of $16.3 MM. This is in addition to a fine previously paid to the UK Financial Services Authority (FSA) in January, 2009 of £5.25 MM (approximately $8.2 MM at today’s exchange rate). The Aon resolution has several factors which are of interest and should be noted by the compliance practitioner.
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