Deutsche Bank Aktiengesellschaft (Deutsche Bank) has agreed to pay in excess of $130 million to settle allegations of FCPA violations and commodities fraud. This is the second time in about as many years that the Frankfurt, Germany-based multinational financial services company has settled FCPA problems with the U.S. government. Deutsche Bank’s trouble this time centered around $7 million in bribes and other inappropriate payments made by Deutsche Bank to foreign officials and their relatives who were engaged as business development consultants, third-party intermediaries and finders who were responsible for getting and retaining business. The conduct dates back to the 2009/2010 financial crisis and serves as a warning about the need for extra compliance vigilance during recessions. See “Deutsche Bank Nepotism Settlement Shows Policies Are Not Enough” (Sep. 18, 2019).