In November 2016, JPMorgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC) resolved its long running Foreign Corrupt Practices Act investigation and enforcement, obtaining a non-prosecution agreement (NPA) from the Justice Department with a penalty of $72M, agreeing to a cease-and-desist order  (Order) from the Securities and Exchange Commission, with a penalty consisting of profit disgorgement and interest of $135 million, and reaching an agreement with the Federal Reserve Bank for a consent cease-and-desist order (Fed Order) to put in place a best practices compliance program and pay a penalty of $61M.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...