Co-Authored by Sharath Patil
Largest FCPA Settlement to Date
The U.S. Securities and Exchange Commission (“SEC”) and the U.S. Department of Justice (“DOJ”) announced in October that Goldman Sachs Group, Inc. (“Goldman Sachs”) agreed to pay $2.9 billion as part of a settlement agreement. The settlement was a result of the agencies’ enforcement action after they learned that Goldman Sachs had allegedly paid $1.6 billion in bribes to officials in Malaysia and the United Arab Emirates (“UAE”) to secure its position as the underwriter of $6.5 billion in three bond deals with 1Malaysia Development Berhad. The settlement constitutes the largest Foreign Corrupt Practices Act (“FCPA”) settlement ever recorded.