FCPA Compliance Report

Eric Young on the Fed and DFS Components of the Goldman Sachs Corruption Enforcement

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In this episode, I am joined by Eric Young, recently retired long-time compliance professional. We explore an under-looked aspect of the Goldman Sachs FCPA enforcement action; the independent enforcement actions by the Federal Reserve Bank and state of New York’s Department of Financial Services. 

Some of the highlights include:                            

  • Why was the Fed involved in the Goldman Sachs FCPA resolution?
  • The Fed Order seemed critical of Goldman Sachs compliance function. Do you find this criticism warranted?
  • Is the ongoing oversight of the Fed typical for this type of case?
  • Why was the state the New York DFS involved in the Goldman Sachs FCPA resolution?
  • What were the separate reporting obligations of the Goldman Sachs compliance function discussed in the DFS Order? Do such obligations exist at the federal level?
  • Were the dates, timing and amounts of these 3 bond offerings red flags?
  • Were the money laundering allegations in funding equally as troubling as the bribery and corruption? 

    • Resources

    Federal Reserve Cease and Desist Order

    State of New York, Department of Financial Services Consent Order

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    FCPA Compliance ReportBy Thomas Fox
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