Abstract:
In 2015 and 2016, two major cases were brought involving improper-hiring practices in violation of the Foreign Corrupt Practices Act (FCPA). In August 2015, the U.S. Securities and Exchange Commission (SEC) brought In re Bank of New York Mellon Corp. (BNY Mellon), which involved a financial-services firm providing improper internships to family members of foreign government officials in the Middle East. This case was the first FCPA action against a financial-services firm and the first FCPA action based entirely on improper hiring and internship practices.
