![]() These actions break down into violation of the FCPA by paying or facilitating the payment of bribes circumvention of internal controls and falsification of books and records. bank account in furtherance of his corrupt offers and promises to bribe foreign officials, through which Leissner intended that the officials would use their official positions to assist Goldman Sachs in obtaining the bond deals and other business.” He also worked to actively conceal “information from financial, legal and compliance executives, including by making misstatements to these executives regarding Low’s role as an intermediary in the bond deals.” This knowing circumvention of the company’s internal controls caused Goldman Sachs books and records to be falsely recorded. Leissner himself “made use of interstate commerce by, among other things, sending wire transfers from a foreign bank account to a U.S. What his actions mean for Goldman Sachs is, at this point, still an open question. He was pretty high up in the organization. Leissner was a partner at Goldman Sachs, a US company. Today I want to consider Leissner’s specific legal violations and what lessons may be garnered for the compliance professional. The SEC settlement was via a Cease and Desist Order (Order). Yesterday, I begin a two-part blog post series on Leissner’s settlement with the Securities and Exchange Commission (SEC) for his role in the facilitation of bribery and corruption in the 1MDB saga, focusing on the actions of Leissner which were violations of the Foreign Corrupt Practices Act (FCPA). I thought Frosty was a good analogy to consider the disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner, as he is certainly back again. In the cartoon version, Frosty heads up to the North Pole to avoid melting. Yet, he promises, “I’ll be back again someday”. ![]() Frosty finally says goodbye to the children as the Sun is heating up and he will melt. ![]() Frosty enjoys roaming throughout town with the children who constructed him, only stopping once at a crosswalk when the policeman directing traffic orders pedestrians to stop. Which is your favorite version – the Jimmy Durante single or the cartoon version narrated by Jimmy Durante? The song recounts the fictional tale of Frosty, a snowman who is brought to life by a magical silk hat that a group of children find and place on his head. ![]()
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