Settling states alleged that Zurich failed to disclose it paid “contingent commissions” to insurance brokers and conspired with brokers at the center of the conspiracy in a “pay-to-play” scheme to overcharge commercial policyholders for their insurance policies. Zurich participated in a scheme devised by broker Marsh & McLennan to give commercial policyholders the illusion of a legitimate competitive bidding process on policies. In fact, Marsh had secretly pre-designated certain insurers to win bids, but the results for the policyholders were actually inflated rates, not best bids. For its part, Zurich showed a willingness to submit fake quotes and was rewarded with protection from competition so it could set artificially high premiums and profit on other lucrative accounts. The brokers also engaged in anti-competitive conduct by steering contracts away from insurance companies that refused to participate in the scheme. The direct victims of the bid-rigging scheme were large and small companies, nonprofit organizations and government offices that purchased commercial lines of insurance from Zurich. The company agreed to to pay $151 million to consujers and $20 million to the settling states, to disclose contingent commissions, and to change its business practices.