Davis Polk secured a deferred prosecution agreement with the Department of Justice Fraud Section for a global financial institution in connection with the DOJ’s investigation into potential manipulative and collusive conduct in the institution’s foreign-exchange business.  The agreement required our client to pay a criminal penalty, disgorgement and restitution.  The criminal penalty reflected a 15% reduction off the bottom of the U.S. Sentencing Guidelines range and significant credit for cooperation and remediation.   

Davis Polk also represented this global financial institution in resolving a parallel investigation by the Federal Reserve Board.  The resolution resulted in a civil money penalty among the lowest of all the financial institutions penalized by the Fed as a result of its investigations into the foreign exchange market.

Copy link to share post