Posted: September 17th, 2015

Foreign Corrupt Practices Act.

Are Wall Street Interns the Latest Regulatory Target?

What is the Foreign Corrupt Practices Act (FCPA) and why is the government alleging that BNY Mellon’s internship program violates the FCPA? Was this internship program similar to other internship programs run by the bank? Assume you were the executive at BNY Mellon, prior to this SEC investigation, charged with deciding whether to have an internship program for family members of foreign clients. Using a framework for ethical decision making , evaluate whether the internships should be permitted. Discuss.

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