There were many new developments this month in the world of anti-bribery compliance.  Read the summaries below and then vote for which one you think is most deserving of the top spot: 

1. Bank of New York Mellon to Pay SEC $14.8 Million to Settle Bribery Charges - the banking and financial services company entered into a settlement agreement with the SEC this month, agreeing to pay $14.8 million in penalties and fines for alleged violations of the Foreign Corrupt Practices Act (FCPA).  The allegations stemmed from BNY Mellon's provision of internships to family members of foreign government officials connected to a Middle Eastern sovereign wealth fund.  Read the full story on the TRACE Compendium.

2. New U.K. Law will Require Private Companies to Disclose Ownership - although it received Royal Assent in March 2015, several provisions of the U.K.'s Small Business, Enterprise and Employment Act 2015 (SBEE) are not yet in force.  Recently it was confirmed that the provision requiring companies "to keep a register of people who have significant control over the company" will come into force in January 2016.  The new law will require an increased level of transparency surrounding ownership of privately-held companies.  Under the law, companies must provide their registers to the Companies House starting in April 2016, and this information will then be made available in a searchable public registry.  

3. Former SAP Executive Pleads Guilty to Bribery of Panamanian Officials - a former SAP executive, Vicente Garcia, pled guilty to DOJ charges of conspiracy to violate the FCPA on August 12, 2015.  The charges stemmed from Garcia's involvement in a scheme to bribe government officials in Panama from 2009 to 2013 in exchange for government technology contracts.  Sentencing is slated to take place in December 2015.  Garcia also agreed to pay over $90,000 to settle a parallel SEC action for violations of anti-bribery and internal controls provisions.  Read the full story on the TRACE Compendium.

4. Donald Trump Calls the FCPA a "Horrible Law" - last month it was reported that in 2012 - prior to his presidential campaign - Donald Trump characterized the FCPA as a "horrible law" and said it should be changed.  Trump criticized the law as putting American companies at a disadvantage.  However, many FCPA experts agree that a change in administration will have little effect on enforcement.

5. DOJ Hires a New Compliance Counsel - at the end of last month, the DOJ revealed that it is hiring for the newly created position of Compliance Counsel.  The Compliance Counsel will help the DOJ evaluate companies' compliance programs and when to move forward with a prosecution of FCPA violations.  If the DOJ does choose to go forward with a prosecution, the Compliance Counsel's evaluation will also come into play when the DOJ assesses a company's remediation efforts.  The DOJ has already selected an individual, and this person is currently being vetted for the position.