The Man From FCPA noted with interest the JPMorgan Chase FCPA settlement last week coming in at a stunning $264 million in fines, penalties and profit disgorgement. A portion of this settlement was paid to the U.S. Federal Reserve Bank, which had never previously occurred in FCPA settlement. While some commentators opined such a fine by the Fed should not be considered a FCPA, if it walks like a duck and quacks like a duck, it is a duck. The Fed sanctioned the bank for its failures under both the FCPA and its own internal compliance regime so it is a FCPA duck.
