More than three years after the investigation of hiring practices at JPMorgan Chase by the SEC became public, the company has settled nepotism-related bribery charges with the SEC, the DOJ and the Federal Reserve. The basic facts have been known since 2013 when The New York Times broke the story, but the further details revealed in the SEC’s cease-and-desist order and the DOJ’s non-prosecution agreement show a pervasive pattern of quid pro quo hirings in the bank’s Asia Pacific subsidiary. We take a look at how the bank’s compliance program failed and how JPMorgan addressed those failures successfully enough to avoid the imposition of a monitor. See “Managing Corruption Risk When Hiring and Training Foreign Officials and Their Relatives Overseas: Practical Compliance Guidance (Part One)” (Jul. 27, 2016); (Part Two) (Aug. 10, 2016).