Action against Respondent, a financial services corporation, for alleged violations of the books and records and internal accounting controls provisions of the FCPA.  According to the SEC, Respondent provided employment to the relatives of foreign government officials to influence them to assist the bank in obtaining or retaining business or other benefits.  The SEC further alleges that Respondent did not enforce a hiring policy enacted to prevent such conduct, that its books and records did not accurately document certain hiring-related expenses, and that it failed to maintain a system of internal accounting controls related to its hiring practices.  Pursuant to a settlement order highlighting Respondent’s cooperation and remedial efforts, Respondent has agreed to pay disgorgement of $10,785,900, prejudgment interest of $2,392,950, and a civil penalty of $3,000,000.

SEC Order