FCPA Charges against Broker-Dealer Stemming From Routine SEC Examination Is “Wake-Up Call” to the Financial Services Industry

A routine SEC examination of a New York-based broker-dealer has resulted in FCPA, Travel Act and money laundering charges against two employees in its Miami office.  It’s the first in which individuals were targeted for bribery during the sale of financial services.  Acting Assistant Attorney General Mythili Raman warned in a statement that the case “is a wake-up call to anyone in the financial services industry who thinks bribery is the way to get ahead.”  In an irregular move in a corruption case, prosecutors also charged the foreign official the employees allegedly bribed with violating the anti-money laundering statutes and the Travel Act.  This article distills the compliance takeaways and summarizes the complaints.

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