Last summer, the FCPA world was treated to its first Princeling hiring prosecution action when the SEC brought an enforcement action against Bank of New York Mellon. BNY Mellon paid a fine of $14.8 million for the hiring of sons and a nephew of two representatives of an un-named sovereign wealth fund. While JPMorgan Chase has garnered the most attention around this issue, probably because of its notorious spreadsheet tracking of son and daughter hires to develop business in China, there are multiple U.S. companies under scrutiny for similar conduct. The FCPA Blog has reported that Credit Suisse, Goldman Sachs, Morgan Stanley, Citigroup, and UBS are all under investigation by the SEC for their hiring practices around the sons and daughters of foreign government officials. BNY Mellon has the honor of being the first company to reach resolution on this issue.
