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What Does This Mean For Credit Suisse?

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As highlighted here and here, in July 2018 Credit Suisse resolved a $77 million Foreign Corrupt Practices Act enforcement action concerning its internship and hiring practices involving family members of alleged Chinese “foreign officials.”

As highlighted here, the DOJ recently unsealed criminal charges against former Credit Suisse bankers (Andrew Pearse, Surjan Singh, and Detelina Subeva) in connection with financing various maritime deals in Mozambique.

The question thus arises: what does this mean for Credit Suisse?

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Former Credit Suisse Bankers Charged With FCPA And Other Offenses In Connection With Various Mozambican Maritime Projects

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Yesterday this criminal indictment was unsealed charging former Credit Suisse bankers Andrew Pearse, Surjan Singh, and Detelina Subeva with conspiracy to violate the FCPA’s anti-bribery and internal controls provisions in connection with financing various Mozambican maritime projects.

In many respects, the action is similar to the November 2018 enforcement action against various individuals associated with Goldman Sachs in connection with Malaysia’s 1MDB fund (see here for the prior post).

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Issues To Consider From The Credit Suisse Enforcement Action

Issues

This post highlighted the recent $77 million Foreign Corrupt Practices Act enforcement action against Credit Suisse concerning its internship and hiring practices involving family members of alleged Chinese “foreign officials.” This post continues the analysis by highlighting additional issues to consider.

Timeline

Credit Suisse’s FCPA scrutiny appears to have begun in late 2013 (see here). Thus from start to finish, its scrutiny lasted approximately 4.5 years.

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Next Up – A $77 Million Enforcement Action Against Credit Suisse

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First, it was BNY Mellon Corp. in August 2015 for $14.8 million (see here and here for prior posts). Then, it was Qualcomm in March 2016 for $7.5 million (see here and here for prior posts). Then, it was JPMorgan in November 2016 for $202.6 million (see here, here, and here for prior posts).

Next up in Foreign Corrupt Practices Act enforcement actions (mostly targeting the financial services industry) focusing, in whole or in part, on internship and hiring practices being a form of bribery is Credit Suisse as the DOJ and SEC officially announced today (see here and here) the expected enforcement action (see here).

If you were wondering whether this “scurrilous and hypocritical” form of FCPA enforcement action (as stated by a former SEC Chairman see here) would carry forward to the Trump administration, you now have the answer.

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What’s Up With The Credit Suisse “Enforcement Action”?

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If a tree falls in a forest and no one is around to hear it, does it make a sound?

The FCPA version of this is: if a company announces an FCPA enforcement action, yet the DOJ/SEC are silent about it, and no document relevant to the enforcement action is in the public domain, has there been an enforcement action?

Perhaps one day the Credit Suisse enforcement action will be formally announced and resolution documents publicly released, but in the meantime, as highlighted below, there is a mystery as to what is going on.

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