Completing a trifecta of settlements with banks for improperly hiring the relatives of foreign officials, the SEC and DOJ recently announced that the Hong Kong investment bank subsidiary of Credit Suisse Group AG (CSAG) has agreed to pay criminal penalties and disgorgement totaling approximately $77 million. The subsidiary entered into a non-prosecution agreement with the DOJ and CSAG resolved charges with the SEC in a cease-and-desist order. We examine the familiar fact pattern as well as the company’s less-than-perfect cooperation and remediation efforts that still resulted in an NPA. See “Hiring Practices and FCPA Compliance in the Wake of the BNY Settlement (Part One of Two)
” (Jan. 13, 2016); Part Two
(Jan. 27, 2016).