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Financial Services Law Insights and Observations

German bank to pay $16.2 million for allegedly concealing corrupt hiring practices

Securities SEC FCPA Settlement Anti-Corruption China Russia


On August 22, a German-based bank entered into an administrative order with the SEC agreeing to pay $16.2 million to settle the SEC’s claims that it allegedly concealed corrupt hiring practices. According to the SEC, the bank allegedly violated U.S. laws—including the internal controls and books and records provisions of the FCPA—by offering jobs to relatives of Chinese and Russian government officials in an attempt to secure business or other benefits. Employees then created false books and records that concealed the practices and circumvented internal controls in place to prevent the activities. The SEC stated that the bank’s failure to properly enforce its written global anti-corruption policy allowed the bank to provide jobs in China and Russia from at least 2006 to 2014 based on how much business the candidate’s connections could bring to the bank.

In entering into the administrative order, the SEC considered the company’s cooperation efforts and compliance efforts. Without admitting or denying wrongdoing, the bank agreed to pay a $3 million civil money penalty and more than $13.1 million in disgorgement and interest.