As highlighted in prior posts here and here, in 2016 JP Morgan resolved a $202.6 million Foreign Corrupt Practices Act enforcement action against J.P. Morgan (and a related entity) based on its alleged improper hiring and internship practices that the U.S. government labeled bribery and corruption.
According to the DOJ, “the so-called Sons and Daughters Program was nothing more than bribery by another name. Awarding prestigious employment opportunities to unqualified individuals in order to influence government officials is corruption, plain and simple.”
Like nearly all modern corporate FCPA enforcement actions, the JP Morgan matter was not subjected to any meaningful judicial scrutiny.