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How JPMorgan Chase avoided prosecution over ‘Sons and Daughters’

Tom Fox | December 13, 2016

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.

The conduct involved JPM-APAC’s Client Referral Program, named the “Sons & Daughters Program,”...

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