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Goldman – Related Developments


As highlighted in this prior post, last week the DOJ and SEC announced a net $1.66 billion Foreign Corrupt Practices Act enforcement action (the largest ever) against Goldman Sachs in connection with the IMDB fund.

As highlighted below, in connection with the same core conduct, the Federal Reserve Board also announced that it had fined Goldman $154 million for engaging in “unsafe and unsound practices.”

In addition, as highlighted below, the SEC issued a temporary order granting Goldman affiliated entities an exemption from the Investment Company Act’s prohibition on serving or acting an investment advisor or depositor upon the conviction of a felony.

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FCPA Institute – Zoom (Nov. 10-12)

FCPA Institute - Zoom

Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of hundreds of professionals from around the world. In the current COVID environment, the traditional two-day, in-person FCPA Institute is not possible.

However, there remains a need for FCPA knowledge and skill development and thus I am pleased to offer the FCPA Institute – Zoom on November 10-12 – an event which has already received registrations from individuals in various countries around the world. The FCPA Institute – Zoom will consist of 9 hours of integrated and cohesive instruction (each day from 9 a.m. – noon central) led by Professor Koehler, an FCPA expert with FCPA practice and teaching experience.

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This Week On FCPA Professor


FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

As highlighted here, the DOJ/SEC announced a net $1.66 billion FCPA enforcement action (the largest ever) against Goldman Sachs in connection with the 1MDB Fund.

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In Terms Of Settlement Amounts, 2020 FCPA Enforcement Has Set An All-Time Record

record breaker

Last year was a record-breaking year in terms of Foreign Corrupt Practices Act settlement amounts as the DOJ/SEC collected approximately $2.65 billion.

With this week’s record-setting $1.66 billion net FCPA settlement involving Goldman Sachs, 2020 has eclipsed 2019 as the DOJ/SEC are poised to collect $2.66 billion in FCPA settlement amounts. This amount is likely to grow with approximately two months left in 2020 as the end of the year historically is an active period for FCPA enforcement.

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The Top Ten List Of Corporate FCPA Settlements

top ten

Yesterday’s net $1.66 billion Foreign Corrupt Practices Act settlement involving Goldman Sachs is the largest in FCPA history.

This post highlights the current top ten corporate FCPA settlements of all-time actually secured by U.S. law enforcement.

This list is calculated after consistently accounting for certain credits or deductions in several enforcement actions involving foreign companies and/or related foreign law enforcement actions.

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