Declinations for global financial institutions involving Asian hiring practices
Davis Polk secured no enforcement action letters from the SEC for three separate global financial institutions in connection with the industrywide Foreign Corrupt Practices Act investigations into hiring practices in Asia, the so-called “princelings investigations.” These multiyear investigations by the SEC also involved inquiries by other U.S. and international regulatory agencies and were focused on whether companies provided preferential treatment to relatives and friends of foreign-government officials in connection with the hiring of candidates. Multiple other financial institutions entered into settlements with regulatory agencies in connection with their hiring practices.
The Davis Polk team included partners Martine M. Beamon, Angela T. Burgess, Denis J. McInerney, Fiona R. Moran, Paul J. Nathanson, Patrick S. Sinclair, Martin Rogers, James Wadham, and counsel Linda Chatman Thomsen. Members of the Davis Polk team are based in the Hong Kong, New York and Washington DC offices.