Significant Remediation Spares Goldman Sachs a Monitor in Biggest FCPA Settlement in History

It has taken two years, but The Goldman Sachs Group has now settled allegations related to its role in the scandal surrounding sovereign wealth fund 1Malaysia Development Berhad for the eye-popping sum of $2.9 billion. But even with combined financial penalties and disgorgement that make it the largest FCPA settlement in history, the bank managed to dodge several bullets in negotiating its deal, due, perhaps, to its extensive remediation efforts. We analyze the unique ways the bank has sought to shore up its compliance program – including executive compensation clawbacks – and how those changes may have influenced the deal. For a detailed analysis of the bribery scheme, see “How a Flamboyant Intermediary Snarled Goldman Sachs in the 1MDB Scandal” (Nov. 28, 2018).

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