Fcpa Compliance Report

  BNY Mellon Up until the summer of 2015, hiring practices under the FCPA were not been given much thought or widely discussed. However that began to change in the summer of 2015 when the SEC announced a resolution with Bank of New York Mellon Corporation (BNY Mellon) for violations of the FCPA. This was the first enforcement action around the now infamous Princess-lings and Princelings investigation where US companies hired the sons and daughters of foreign officials to curry favor and obtain or retain business. In this matter the BNY agreed to pay $14.8 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by providing valuable student internships to family members of foreign officials affiliated with a Middle Eastern sovereign wealth fund. The Order also specified how the hiring of the relatives led directly to BNY Mellon obtaining and retaining business. One foreign official, made a personal request that BNY Mellon provide internships to two of his relatives: his son and ne