On December 20, 2012, the SEC published a litigation release in this matter. The SEC alleged that "Aon's subsidiaries 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 those countries." The SEC alleged that Aon subsidiaries made payments in several countries including "Costa Rica, Egypt, Vietnam, Indonesia, United Arab Emirates, Myanmar, and Bangladesh." Aon allegedly realized over $11.4 million in profits from the payments.

In the Complaint, the SEC alleged that: "From as early as 1983 until as recent as 2007, subsidiaries of Aon Corporation ('Aon' or the 'Company') in numerous countries made improper payments to various parties as a means of obtaining or retaining insurance business in those countries. During this period, over $3.6 million in such payments were made, including some directly or indirectly to foreign government officials who could award business directly to Aon subsidiaries, who were in position to influence others who could award business to Aon subsidiaries, or who could otherwise provide favorable business treatment for the Company's interests." The Complaint alleged improper payments to employees of foreign government-owned clients and third parties in Costa Rica and Egypt and improper payments to third-party facilitators in Vietnam, Indonesia, United Arab Emirates, Myanmar, and Bangladesh.

On December 22, 2011, Federal District Judge Amy Berman Jackson entered final judgment against Aon Corporation pursuant to the consent of Aon Corporation.