2011 Ends With Over $100 Million in Penalties and Disgorgements for FCPA Violations at Insurance Company and Telecom Company

Morrison & Foerster LLP

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.

Please see full alert below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morrison & Foerster LLP | Attorney Advertising

Written by:

Morrison & Foerster LLP

Morrison & Foerster LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.