The Foreign Corrupt Practices Act (FCPA) is often associated with payoffs between shadowy figures for contracts made in remote parts of the world. But a spate of recent prosecutions and civil settlements makes clear that the financial services industry is in fact a significant target for potential violations of this centerpiece compliance legislation.

One need look no further for affirmance of this point than the SEC’s July 5, 2018 announcement of a $29.8 million settlement of claims against Credit Suisse Group for (the SEC asserts) hiring “relatives and friends of foreign government officials as a personal benefit to the requesting officials in order to obtain or retain investment banking business or other benefits” for Credit Suisse.

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