On July 5, 2018, federal authorities announced a non-prosecution agreement with Credit Suisse (Hong Kong) Limited (“CSHK”) in connection with alleged FCPA violations stemming from the bank’s hiring of friends and relatives of Chinese government officials between 2007 and 2013. According to admissions made by CSHK, senior managers in the bank’s Asia-Pacific region hired and promoted candidates referred to them by government officials to win investment banking business. In some cases, so-called “relationship hires” or “referral hires” were reportedly less qualified than other candidates, were subjected to less rigorous vetting, or were otherwise treated more favorably due to their connections. CSHK admitted that these hiring practices helped the bank obtain at least $46 million in profits. CSHK has agreed to pay a criminal penalty of over $47 million to resolve the matter. Additionally, CSHK and parent Credit Suisse Group AG have agreed to continue to cooperate with DOJ, to enhance their compliance programs, and to report to DOJ on the implementation of enhanced compliance measures. In outlining the resolution, authorities noted that CSHK did not voluntarily and timely disclose the conduct, and characterized its cooperation as “reactive” rather than proactive.