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