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Foreign Corrupt Practices Act & Anti-Corruption


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  • New Survey Reports on Corruption in the Asia Pacific Region

    Transparency International, a German nonprofit that tracks global corruption and perceptions of corruption, has published People and Corruption: Asia Pacific – Global Corruption Barometer. In what the organization calls “the most extensive survey of its kind,” the group spent a year and a half interviewing over 21,000 people living in the Asia Pacific region as a litmus test for corruption in the area.  The 38-page report found considerable differences in bribery rates between surveyed countries; for example, while Japan weighed in at 0.2%, a staggering 69% of people surveyed in India indicated they had paid a bribe in the past year in exchange for public services.  People across the surveyed region agreed that police were the most corrupt part of public services.  While Australians expressed the “most positive” outlook on corruption, people in Malaysia and Vietnam felt the least positive overall, and people in China “were most likely to think the level of corruption had increased recently.”  The report outlines three key recommendations, encouraging governments to “make good on promises,” “stop[] bribery in public services,” and “encourag[e] more people to report corruption.” 

    FCPA Update Germany Asia Japan Corruption

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  • Large International Bank Discloses SEC and DOJ Investigations Into its Hiring Practices in Asia

    On March 1, a large international bank based in the U.K. disclosed in its annual report that it is being investigated in connection with its hiring practices in Asia.  In disclosing both DOJ and SEC investigations, the bank noted that it is cooperating with the investigations and "keeping certain regulators in other jurisdictions informed." While not explicitly linking the hiring probe to the FCPA, the acknowledgement appears to be the latest by an international financial institution concerning U.S. investigations into FCPA implications of its hiring practices in Asia and continues the long-running "Sons and Daughters" investigations by the SEC.  Prior FCPA Scorecard coverage of other aspects of the "Sons and Daughters" investigation around the world is available here. Separately in its annual report, the U.K.-based financial institution also stated that the "DOJ and SEC are undertaking an investigation into whether the [bank's] relationships with third parties who assist [the bank] to win or retain business are compliant with the" FCPA.  The bank disclosed that it has briefed regulators in other jurisdictions about these investigations.

    Asia Sons and Daughters

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  • Large Multinational Financial Services Company Settles FCPA Charges Relating to Internships

    On Tuesday, August 18, the SEC announced a settlement with a large multinational financial services company over allegations that the company had violated the FCPA by giving internships to family members of government officials working at a Middle Eastern sovereign wealth fund in hopes of retaining or gaining more business from that fund.  The order entered as part of the settlement quoted emails between company employees purportedly demonstrating that the company gave the internships in hopes of keeping and growing the business relationship with the fund.  The SEC also alleged that the company gave the internships to the family members without requiring that they pass through the competitive screening process the company typically requires for interns.  Finally, the SEC alleged that the company had inadequate controls to prevent the improper hiring of relatives of government officials.  The company paid $14.8 million to settle the charges, with $8.3 million in disgorgement, $1.5 million in pre-judgment interest, and a $5 million penalty. The company previously disclosed in January 2015 that it had received a Wells Notice concerning possible FCPA violations in connection with the internships.  The settlement follows earlier press reports of a broad SEC investigation into bank hiring practices in Asia, and appears to be the first settlement resulting from the investigation.

    Settlement Asia BNY Mellon

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