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CORRESP
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November 15,
2005

VIA EDGAR AND
OVERNIGHT MAIL

Ms. Cecilia
D. Blye

Chief,
Office of Global Security Risk

Division
of Corporate Finance

Securities
and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:                             Aon
Corporation

Form 10-K
for the Fiscal Year Ended December 31, 2004

Response
Letter Dated June 2, 2005

File No. 1-07933

Dear Ms. Blye:

I write in response to your letter
dated October 18, 2005.  In your
letter, you requested that Aon Corporation provide information regarding: (1) whether
any of its subsidiaries have, or have had, operations in Sudan and whether such
operations pose a risk to Aon’s reputation and share value; and (2) whether
Aon’s non-U.S. subsidiaries’ operations in Iran pose a risk to Aon’s reputation
and share value in light of certain recently enacted or proposed state
legislation.

1.                                      Sudan

Aon Corporation’s U.S. subsidiaries do not do business
in Sudan, in accordance with U.S. law.
As Aon previously informed Staff, prior to April 1, 2005, some Aon non-U.S.
subsidiaries had done a very small amount of business relating to clients or
transactions in Sudan, but as of April 1, 2005, Aon Corporation adopted a
policy requiring even its non-U.S. subsidiaries to terminate any business
relating to Sudan or Burma.  Although
non-U.S. subsidiaries have been permitted to undertake this process in an
orderly manner – e.g., non-U.S.
Aon insurance brokerage subsidiaries, consistent with their obligations as
brokers, are not dropping clients in the middle of the year prior to annual
policy renewals but are instead advising clients to hire new brokers for such
renewals – even these sorts of limited and transitional activities will soon
cease.  Because Aon has adopted a policy
forbidding even its non-U.S. subsidiaries from doing business in Sudan, Aon
does not believe that any remaining activities by

these subsidiaries relating to Sudan pose a current
risk to its reputation or share value.
In addition, Aon believes that its new policy is consistent with the
legislation referenced by the Staff requiring divestment from, or reporting of
interests in, companies that do business in Sudan.

2.                                      Iran

Aon Corporation’s U.S. subsidiaries do not do business
in Iran, in accordance with U.S. law.
With respect to its non-U.S. subsidiaries, as previously disclosed to
the Staff, earlier this year Aon Corporation senior management commissioned a
report evaluating whether to terminate even its non-U.S. subsidiaries’
activities relating to Iran.  Aon’s
Compliance Department has conducted interviews and gathered information from
our non-U.S. business units and is currently in the process of preparing this
report.  The report will be delivered to
senior management at the end of the year, and will take into consideration, inter
alia, whether Aon’s non-U.S. subsidiaries’ activities relating to Iran
might have an adverse effect on Aon Corporation’s reputation or share
value.  In particular, our Compliance
Department has reviewed the legislation adopted by the states of Arizona and
Louisiana and will monitor whether other jurisdictions adopt similar
legislation.  As our Compliance
Department is still in the process of preparing the report for senior
management, it would be premature to make a commitment to the Staff with
respect to the future of our non-U.S. subsidiaries’ operations in Iran or Aon’s
position on whether such legislation might have an adverse effect on its
reputation or share value.  However, at
this time, we have been unable to discern any adverse effect on our reputation
from the legislation in Arizona and Louisiana or the proposed legislation in
other states.

If you have any questions
with regard to these responses, need further supplemental information, or want
to discuss any of the matters covered by this letter, please do not hesitate to
contact me.

  Very truly yours,

  /s/ D. Cameron Findlay

  D. Cameron Findlay

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