o Engaged in "two sham insurance transactions" that gave investors the impression the company had larger reserves for claims than it did. The transactions, personally approved and negotiated by Mr. Greenberg, the complaint alleges involved the CEO of General Reinsurance Corporation, Inc.

o Hid loses from its underwriting business by converting the underwriting loses into capital loses.

o Created false underwriting income that involved false reporting of income from the purchase of life insurance policies as underwriting polices. This scheme was personally approved by both Mr. Greenberg and Mr. Smith.

The complaint further claims that Mr. Greenberg manipulated AIG's stock price, instructing traders to "aggressively purchase" the stock and increase the worth of his and Mr. Smith's holdings.

The company is accused of booking workers' compensation insurance premiums as regular liability insurance revenue, which may have reduced AIG's contribution to the state's workers' comp system and avoided payment of taxes on the premiums.

AIG also is accused of deceiving New York state and other insurance regulators about offshore relationships with reinsures. Documents related to this investigation were destroyed by AIG, the suit alleges.

The complaint seeks payment of punitive damages and court costs, restitution and other payments without specifying any amounts.

Joe Norton, director of public relations for AIG, said the company has reviewed the complaint and is pleased the attorney general noted the company's continued cooperation in the investigation.

"There are no new claims raised in the complaint," he said, adding Mr. Spitzer has "previously indicated his expectation of reaching a civil settlement with AIG."