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?