Compliance Guide

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Goldman Sachs Fined 36.3 Million Dollars in Case Over Leaked Documents

August 5 – Goldman Sachs Group was ordered by the Federal Reserve Board to pay a $36.3 million civil money penalty for its unauthorized use and disclosure of confidential supervisory information and to implement an enhanced program to ensure the proper use of confidential supervisory information.

Additionally, the board announced that it is instituting enforcement proceedings against Joseph Jiampietro, a former managing director at Goldman Sachs, seeking to impose a fine and permanently bar him from the banking industry stemming from his and his subordinates’ unauthorized use and disclosure of confidential supervisory information.

Confidential supervisory information includes reports of bank examinations and other confidential reports prepared by banking regulators. It is illegal to use or disclose confidential supervisory information without prior approval of the appropriate banking regulator.

In levying the fine on Goldman Sachs, the board found that the firm’s personnel improperly used confidential supervisory information in presentations to its clients and prospective clients in an effort to solicit business for the firm. Further, the board found that from at least 2012, the firm did not have sufficient policies, procedures or adequate employee training in place to ensure compliance with current laws prohibiting the unauthorized use or disclosure of confidential supervisory information.

The board’s order requires Goldman Sachs to put in place an enhanced program to ensure compliance with regulations concerning the receipt, use and dissemination of confidential supervisory information. The board of directors of Goldman Sachs must ensure that its senior management implements an effective compliance risk management framework and that potential compliance risk failures are appropriately brought to the attention of senior managers and addressed immediately, according to the order.

Goldman Sachs is prohibited by the order from re-employing individuals involved in the improper disclosure of confidential supervisory information or retaining them as consultants or contractors. In November 2015, the board permanently barred a former Goldman Sachs employee from the banking industry following his guilty plea for the theft of confidential supervisory information.

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