On April 13, the U.S. Securities and Exchange Commission brought
an enforcement action under the Foreign Corrupt Practices Act
against Asante Berko, a former executive of a U.K. subsidiary of Goldman Sachs Group Inc., for allegedly
coordinating a bribery scheme to help a client of the subsidiary
win a contract to build and operate an electrical power plant in
Ghana.1
According to the complaint, although an intermediary paid
multiple bribes to secure the business, Goldman's compliance
division ended the bank's involvement in the deal based on
concerns about that intermediary. The SEC did not charge either
Goldman entity, noting in its press release that the
"firm's compliance personnel took appropriate steps to
prevent the firm from participating in the
transaction."2
