Up until the summer of 2015, hiring practices under the FCPA were not being given much thought or widely discussed. However, that began to change in the summer of 2015 when the SEC announced a resolution with Bank of New York Mellon Corporation (BNY Mellon) for violations of the FCPA. This was the first enforcement action around the now infamous Princess-lings and Princelings investigation where US companies hired the sons and daughters of foreign officials to curry favor and obtain or retain business.
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