December 13, 2018
  • 2:07 am Explainer: Swiss Law Protects Crime
  • 2:06 am Credit Suisse infiltrated government, received billions of dollars
  • 2:05 am CS on the Brink of the Abyss: Traders Run Amok
  • 2:04 am Public Entrance Goes Nowhere
  • 2:03 am Deep Bank Crime Whitewash

Credit Suisse infiltrated government Received billions of dollars of business

This bank has been caught again, and again ….. doing criminal corruption.

This time,  it “infiltrated” government owned corporations in China by “hiring” relatives of their executives who gave the bank billions of dollars of business. The “hires” were often so incompetent that those associated with them observed that “corruption was a way business got done”.

The practice is reminiscent of earlier scandals where the “offending person/s” lacked relevant skills and was illegitimately appointed to manage billion-dollar accounts.

Here follow some extracts from the SEC Report – which is largely a copy/paste from the DOJ Statement of Facts.

What is striking is how obvious and normal it all seems for this criminal bank – a massive number of supposedly “innocent” bank officers participated in the elaborate corruption, but never said “boo” or were reprimanded, or reported the matter to a “whistle-blower line” or were prosecuted (shock, horror at even the thought). In brief:

Nothing happened to cause this extreme evil to attract significant public attention (i.e. a vote winning issue – NOT).

It followed an often repeated script (or “deep state conspiracy if you prefer) where monstrous crimes both proven and indicated were white-washed with pocket money “fake penalties” and “laughable public apologies”.

The bank even wrote the “penalty offer” which the SEC accepted (page 1 of the SEC Report):

“Credit Suisse has submitted an Offer of Settlement (the “Offer”) which the Commission has determined to accept ….. “

26.    asking whether Employee A could “check with [Foreign Official A] as to whether we can move things to the next step at the same time?” After stating “not too many interviews,” and explaining that Referral Hire A was “a princess [who was] not used to too many rounds of interview,” Employee A proposed “giv[ing] her the offer letter asap,” at which point Employee A would “push her mum [Official A].” In order to make Referral Hire A’s application appear more presentable, Credit Suisse HK bankers drafted a resume for her requiring them to be a bit “creative” in filling in the details.

Referral Hire A exhibited unprofessional behavior. In connection with a July 2010 training, Credit Suisse employees complained that she failed to attend a mandatory boot camp, brought her mother to training events, and left early. One Credit Suisse employee wrote that she received the worst grade in the class on an assessment, commenting that “from the looks of her assessment she didn’t even try (she filled in a pattern of 5As in a row, 5 Bs in a row, etc. on the answer key).” Less than a month later, in or around early August 2010, Referral Hire A and another intern made “the same exact error which nobody makes” on a homework assignment, and it was “apparent that they shared an Excel file and cheated on the homework.” On or about August 5, 2010, after a Credit Suisse employee reported that Referral Hire A “has been leaving at 4 pm right after every lecture every day this week while the rest of the class is working until at least 9pm, 10 pm” and that she “has yet to show up to training today,” Employee B commented, “[Referral Hire A] is the most famous intern ever.” Notwithstanding these performance issues during the probationary period, in or around early October 2010, Referral Hire A’s employment was fully approved, and both Employee A and another employee vouched for her performance.

30.    Credit Suisse managing director emailed Employee B that the managing director was “at a complete loss as to what to write for” Referral Hire A’s evaluation, asking, “[h]as anything been written on her file previously that we could copy and paste?” The two then proposed feedback for Referral Hire A: “Pls come to the office more often — we would like to see more of your smiling face,” and, “Come to the office, answer your phone, don’t be rude…” On or about June 22, 2011, a Credit Suisse employee emailed Employee B, attaching “manager summaries for everyone but [Referral Hire A],” along with the message, “I’m wondering if we can explain that she’s a special situation and there’s no need to give feedback.” Despite this, on or about June 30, 2011, Credit Suisse awarded Referral Hire A a bonus of approximately $58,000.

More extracts are copied below.

The big media reports were generally terrible giving little detail & not offending the bank – when that is what their role required.

We are not “used to it” or “tired of hearing about more bank crime” – action is needed and an independent media should be at the forefront – not cowering complicit cowards.

“Little media” was better:

Brian Monroe at the Association of Certified Financial Crime Specialists wrote a quite decent report (but who reads it?)

Closed circulation BreakingViews (bought by Reuters in 2009) had a good report by Jeffrey Goldfarb, but only a shorter version was published by Reuters. The more complete piece is available via NASDAQ.

Of the big media reports, Bloomberg was the best of a sorry bunch.

You can check for yourself if you have nothing better to do:

Reuters

NY Post

New York Times

Wall St Journal

SEC Press Release

The bank’s propaganda spokeswoman issued a highly dubious statement:

Credit Suisse spokeswoman Nicole Sharp said in a statement that the bank is “pleased to have reached an agreement” with the SEC and has already imposed new standards to end referral hires.“This puts this legacy matter behind the bank, and represents no material impact to Credit Suisse,” Sharp said. “No criminal charges were brought, and there is no allegation that any clients, investors or counterparties were harmed by the conduct involved in the settlements.”

The Chinese people whose hard labour was squandered on mega-corruption were harmed.

The bank’s competitors who lost business were harmed.

Perhaps these people don’t count?

Since they are unlikely to find out the whole truth, Madame Propaganda may be close to the mark in claiming that more Credit Suisse crime being exposed: “represents no material impact to Credit Suisse” – perhaps other banks will feel justified in ever dirtier tricks and ordinary cynical people may become more susceptible to lying politicians.

SEC’s order – Main Points

Abbreviations:
APAC – Asia-Pacific region
FCPA – Foreign Corrupt Practices Act
SOEs – (Chinese) state-owned entities
LCD or legal and compliance – Credit Suisse’s Legal and Compliance Department

Extracts:

Credit Suisse managers in APAC engaged in a practice of hiring, promoting and retaining government-connected Referral Hires as part of a quid pro quo by which Credit Suisse managers sought to improperly influence foreign officials to assist Credit Suisse in winning lucrative investment banking mandates.

senior Credit Suisse managers repeatedly took steps to onboard Referral Hires from SOEs and government ministries independently from the scrutiny of the company’s established, merit-based campus recruiting program.

hiring the Referral Hire would “bring [Credit Suisse] the big surprise in the near future

Need a favor from you. [The Referral Hire] will get us a US$1bn bond deal from [a prospective client].

Credit Suisse managers in the U.S. were aware of Credit Suisse HK’s hiring of client referrals, some of whom treated the job as a mere “boondoggle” (unnecessary, wasteful, fraudulent). For certain Referral Hires, Credit Suisse senior managers in the U.S. approved the hire and took him or her on in the United States. This led to complaints from Credit Suisse U.S. bankers due to the frequency of the requests and the poor quality of the Referral Hires. For example, one senior U.S. Credit Suisse banker wrote: “. . . to be honest, we have had really bad experiences with many of the individuals from Asia .

Credit Suisse failed to take adequate steps to mitigate known risks of bribery and corruption in its APAC operations.

a Credit Suisse employee explained: “Relationship hires have to translate to $” or “the relationship is worthless to our organization.” This email was forwarded to a senior Credit Suisse banking official in the U.S. In a different email, a senior Credit Suisse banker stated that a referral hire “will get us a US$1bn bond deal. . . . His family requested to change his status to permanent with CS

23.    Credit Suisse’s Referral Hires often lacked technical skills, were less qualified, and had significantly less banking and other relevant experience than candidates hired through Credit Suisse’s other employment channels.

Credit Suisse HK hired the nephew of a senior Chinese government official, despite the fact that the nephew lacked investment banking qualifications and a Credit Suisse HK manager acknowledged that “most likely he will not be good.”

this particular individual should be hired in order to “open doors on SOE fronts which we are in lack of

Credit Suisse HK employee explained: “the girl is [the] relative of someone staying at core decision making circle of [the SOE] . . . . this girl is particularly important for . . . us to be blessed by the [SOE].” After the hire the SOE awarded Credit Suisse HK multiple mandates that yielded over $12 million in net profits for the bank.

Credit Suisse HK employed an individual closely connected to a key government minister. The Referral Hire worked at Credit Suisse HK in various roles from June 2010 until December 2012. Credit Suisse HK was awarded lucrative roles in a securities offering for two Chinese SOEs as a consequence of this hire, and received net profits for its work of more than $4 million.

·the company hired the son of a senior commerce minister in China. A Credit Suisse HK senior manager strongly advocated hiring the son, stating that the company’s relationship with the government ministry was “very important” because all “red chip” deals [involving companies based in mainland China but incorporated elsewhere and listed on the Hong Kong Stock Exchange] “need to get approved there.” The bank proceeded to employ the son for over a year, and during his employment one of the senior managers used her “chit” with the minister to assist the bank in securing the necessary approval from the ministry for a deal on which Credit Suisse eventually received net profits of approximately $6 million.

26.    asking whether Employee A could “check with [Foreign Official A] as to whether we can move things to the next step at the same time?” After stating “not too many interviews,” and explaining that Referral Hire A was “a princess [who was] not used to too many rounds of interview,” Employee A proposed “giv[ing] her the offer letter asap,” at which point Employee A would “push her mum [Official A].” In order to make Referral Hire A’s application appear more presentable, Credit Suisse HK bankers drafted a resume for her requiring them to be a bit “creative” in filling in the details.

“I am seeing [Official A] to push. [Official A] will get us in the deal.” Two days later, Employee A sent another email, again using a shorthand reference to Company A in the subject line, writing, “I am meeting [Official A] . . . tomorrow. Where is [Referral Hire A’s] contract?” A Credit Suisse employee responded that the offer letter was being prepared, and a Credit Suisse HK Human Resources manager (“Employee B”) subsequently confirmed Referral Hire A would receive a first year analyst salary and a housing allowance, respectively approximately $70,000 and $30,000 annually. In or around April 2010, Credit Suisse booked the mandate for Company A, realizing a $950,000 fee.

28.    Referral Hire A began working at Credit Suisse, without being vetted or approved by LCD. During her probationary period, Referral Hire A exhibited unprofessional behavior. In connection with a July 2010 training, Credit Suisse employees complained that she failed to attend a mandatory boot camp, brought her mother to training events, and left early. One Credit Suisse employee wrote that she received the worst grade in the class on an assessment, commenting that “from the looks of her assessment she didn’t even try (she filled in a pattern of 5As in a row, 5 Bs in a row, etc. on the answer key).” Less than a month later, in or around early August 2010, Referral Hire A and another intern made “the same exact error which nobody makes” on a homework assignment, and it was “apparent that they shared an Excel file and cheated on the homework.” On or about August 5, 2010, after a Credit Suisse employee reported that Referral Hire A “has been leaving at 4 pm right after every lecture every day this week while the rest of the class is working until at least 9pm, 10 pm” and that she “has yet to show up to training today,” Employee B commented, “[Referral Hire A] is the most famous intern ever.” Notwithstanding these performance issues during the probationary period, in or around early October 2010, Referral Hire A’s employment was fully approved, and both Employee A and another employee vouched for her performance.

29.    Order book is above $900m.” Employee A responded, “[Referral Hire A] is a star” who “also will help us to get [a] USD2bn [initial public offering (“IPO”)],” adding that they should “say we will promote her to associate 1 if she delivers.” On or about April 18, 2011, shortly before Credit Suisse hosted a dinner in Paris for “[Foreign Official A] and her delegation” (including Referral Hire A), Employee A emailed a colleague that Referral Hire A was Foreign Official A’s daughter and that they “will promote her to associate soon as she will bring some sizeable IPO mandates to CS.”

30.    Credit Suisse managing director emailed Employee B that the managing director was “at a complete loss as to what to write for” Referral Hire A’s evaluation, asking, “[h]as anything been written on her file previously that we could copy and paste?” The two then proposed feedback for Referral Hire A: “Pls come to the office more often — we would like to see more of your smiling face,” and, “Come to the office, answer your phone, don’t be rude…” On or about June 22, 2011, a Credit Suisse employee emailed Employee B, attaching “manager summaries for everyone but [Referral Hire A],” along with the message, “I’m wondering if we can explain that she’s a special situation and there’s no need to give feedback.” Despite this, on or about June 30, 2011, Credit Suisse awarded Referral Hire A a bonus of approximately $58,000.

Referral Hire A’s mother accompanied her to Credit Suisse trainings in New York, traveled with her on Credit Suisse business trips, approved a list of client deals for her to work on, and requested that she be promoted by Credit Suisse. For example, in or around May 2012, Employee A and a another Credit Suisse HK senior investment banking manager (“Employee D”) had a meeting with Foreign Official A, during which Foreign Official A approved a list of Credit Suisse clients with whom Referral Hire A could work, including SOE A

Referral Hire A was promoted to the rank of Associate. Approximately one week later, Employee A reported to another banker that Foreign Official A stated that Foreign Official A would execute a “block [trade]” with Credit Suisse. Employee A added a request to “[p]ls keep this confidential for now.”

Credit Suisse employees took steps to attribute credit for certain deals to Referral Hire A, even where she did not contribute any work to those projects. For instance, on or about July 25, 2012, Employee A drafted an email that Employee A directed Referral Hire A to send back to Employee A and other Credit Suisse managers to make it appear as though Referral Hire A had worked to win a mandate from SOE A for the privatization of another Chinese energy-related SOE. After the email was sent, Employee A forwarded it to various Credit Suisse employees, giving them the false impression that Referral Hire A had herself worked to secure the deal and drafted the email. ………….  “[W]e know you made this deal possible for us.” Shortly thereafter, on or about August 6, 2012, Credit Suisse received the mandate to act as joint bookrunner with the other international investment bank on the SOE A equity block trade and convertible bond offering promised by Foreign Official A in July. This transaction generated approximately $2,680,733 in revenue for Credit Suisse.

Employee A emailed Employee C and Employee D with the message, “Btw — [Foreign Official A] mentioned about [Referral Hire A]’s promotion to VP again.” On or about August 17, 2012, Employee A emailed Employee C and Employee D, directing them to “send an email to [Referral Hire A] on [SOE A] . . . [t]hank[ing] her and her mum for the deal.” On or about August 27, 2012, Employee A inquired about when Referral Hire A could be promoted to “Associate 2,” and Employee B agreed

35.    Credit Suisse’s LCD e-mailed a series of questions relating to Referral Hire A’s employment, including “her background, level of experience and qualifications,” “[a]ny record of any external third party/ personal referee referring, recommending or endorsing her for the position,” “[w]ho in Credit Suisse interviewed her,” “[w]ho in Credit Suisse approved her hire,” and “[w]hat … her annual performance ratings” were. Nevertheless, Referral Hire A remained at Credit Suisse until May 31, 2015. During her tenure at Credit Suisse, Referral Hire A received multiple promotions, and Credit Suisse “fast tracked” her promotions by changing her class year. In total, Credit Suisse paid Referral Hire A over $1 million in total compensation.

Credit Suisse offered employment to Referral Hire B, the daughter of an influential official with a powerful Chinese government ministry (“Official B”). Credit Suisse employees decided to recommend hiring Referral Hire B after Employee D forwarded the individual’s resume to colleagues and recommended that Credit Suisse HK “take an exceptional decision to enroll [Referral Hire B] into our first year analyst program this year.” In his recommendation Employee D emphasized that Official B was “very powerful” and “extremely influential in all the banking restructurings/IPOs.” Employee D specified a mandate sought by Credit Suisse HK and stated that Official B would be “very influential” in awarding it. Employee D made these recommendations prior to any interview or other vetting of Referral Hiring B.

Employee A authorized a Credit Suisse recruiting specialist to offer Referral Hire B an 18-month contract for a full-time paid position eligible for bonuses and a relocation allowance. Shortly thereafter, a Credit Suisse HK senior manager informed Official B about her daughter’s offer. Referral Hire B began working at Credit Suisse in March 2010, without having received any screening or approval from LCD or any other compliance body

38.    Credit Suisse staffed Referral Hire B on deals where it was believed her mother could be useful. Credit Suisse HK senior managers and other Credit Suisse employees sought to use Referral Hire B’s connections to her mother to secure business for Credit Suisse, and provided Referral Hire B with promotions and high performance ratings in connection with these efforts.

39.    shortly before Credit Suisse secured a lucrative IPO mandate from aChinese financial SOE (“SOE B”), a Credit Suisse HK senior manager e-mailed Referral Hire B to “[g]et your mum a full set of the docs which we gave to [the chairperson of the financial SOE] when she is back!” In May 2011, a Credit Suisse HK senior manager sent an e-mail to Credit Suisse employees encouraging them to “make sure [Referral Hire B] gets involved in all the meetings” related to the potential deal with SOE B due to her relationships which “will be very important to position us on the overall progress.” Subsequently, in May 2011, Credit Suisse secured the mandate from SOE B, generating approximately $8,961,177 in revenue for Credit Suisse.

40.    Credit Suisse HK senior manager sent an e-mail to various Credit Suisse employees, noting that “[Referral Hire B] was instrumental in helping us to secure [the mandate from SOE B]” and directing them to “invite [Referral Hire B] (e-mails) on all communications” as she was feeling “left out” and a Credit Suisse HK senior manager “[w]ant[ed] to keep [Referral Hire B] happy :).” Less than a month later, Referral Hire B’s performance rating was upgraded from A to AA.

Credit Suisse HK senior manager e-mailed colleagues with a subject heading including the words, “Don’t forward-Confidential” writing that the SOE promised to “give CS the JGC [joint global coordinator] and JBR [joint bookrunner] role in the IPO, based on Referral Hire B’s family’s contribution” to the SOE B.

42.    Referral Hire B routinely requested and was granted special accommodations. When she requested to take a training course in New York, she was permitted to do so, even though Credit Suisse managers believed a comparable Hong Kong course would be more appropriate. Referral Hire B performed poorly at the New York training, completing only 4 out of 16 training modules, scoring a 64% on her exam, and receiving an “Average” grade, placing her in the bottom 14% of her class. Despite this, Referral Hire B was given repeated job promotions by Credit Suisse.

43.    Notwithstanding Referral Hire B’s relationship to a foreign official, Credit Suisse employees did not disclose her background to LCD. In May 2011, over a year after Referral Hire B began her employment, a senior Credit Suisse banker inquired with whom Referral Hire B was affiliated, as the banker “[d]idn’t see that in our RH [Referral Hire] file/list.” Employee B replied that Referral Hire B’s mother was the “current #1 or 2” of the Chinese government ministry. In response, the Credit Suisse banker asked if they could “share this with LCD,” to which Employee B responded, “I would prefer not to unless there is a clear conflict” and added that he doubted Referral Hire B was qualified for the position, noting that he had “doubts about her abilities beyond getting a meeting and completing a ppt slide for a pitchbook” and that “if you have met her you might not even believe that!” He also acknowledged that it would be improper to ask Referral Hire B’s mother to take actions on the company’s behalf, noting, “[I]f we must [disclose Referral Hire B’s relationship to LCD], think it is fair to share this as long as we don’t ask her Mom to do or sign anything?” Nevertheless, Referral Hire B remained employed at Credit Suisse until 2016.

44.    In October 2007, after receiving a resume for Referral Hire C, Employee D emailedthree colleagues: “This is the candidate referred by [Official C, a high-ranking official at SOE C].” On or about November 27, 2007, Employee D emailed a senior Credit Suisse manager about Referral Hire C and another referral hire candidate, writing: “We’re seriously approached by two important clients or business partners for jobs,” noting that one of the candidates was “referred by [Official C, a high-ranking official at SOE C].” After proposing that they offer each candidate “a 3 month intern opportunity,” Employee D added, “Btw, we’re expecting two mandates (one equity and one m&a) from SOE C later this year and it’s an important account for us longer term.” On or around December 17, 2007, Credit Suisse gave Referral Hire C a three-month employment contract.

On or about March 4, 2008, multiple Credit Suisse senior managers had dinner with Official C, during which an upcoming IPO by SOE C was discussed. After dinner, Official C spoke to at least one of the Credit Suisse senior managers about permanent employment at Credit Suisse for Referral Hire C. The following day, that Credit Suisse senior manager notified a colleague that Official C would send an email about Referral Hire C to a Credit Suisse employee, and added: “We’re pitching for the [SOE C] IPO, a multi billion dollar IPO. . . .” In another email, Employee D requested support for Referral Hire C’s hire, noting “we’re pushed by [OfficialC],” and reiterating that Credit Suisse was pitching for the SOE C IPO. Less than two weeks later, or about March 17, 2008, Credit Suisse provided Referral Hire C a full-time position in Hong Kong with a salary of approximately $90,000. In May 2008, Credit Suisse received the mandate from a subsidiary of SOE C to act as bookrunner on its IPO, generating approximately $21,090,349 in revenue for Credit Suisse upon the closing of the deal in 2009. Credit Suisse was also awarded a mandate to act as financial advisor on a SOE C-related merger and acquisition in May 2008, earning approximately $225,000.

46.    During Referral Hire C’s four-year employment at Credit Suisse, senior managers repeatedly emphasized to their colleagues the importance of including Referral Hire C in all matters related to SOE C, referring to ways Referral Hire C could be “leveraged” or included on transactions for which Referral Hire C lacked relevant banking experience and expertise.47.    In or around November 2008, several senior managers decided to eliminate the positions of several highly-rated, regular analysts in order to keep client referral hires linked to banking mandates expected in the next year. Employee D wrote that with respect to Referral Hire C and two other candidates, “we’ll see real relationship revenue coming in the next 12 months if we show good will to them at this critical moment.” In or around March 2009, Credit Suisse was awarded a mandate by SOE C that brought in $1,179,906.48.    On or about May 17, 2010, Employee D emailed three senior colleagues that “[Official C was] ready for [a SOE C affiliate] to do the block [trade] next month, aiming to raise [funds] via an asset injection. . . . He will ask [the SOE C affiliate] to arrange a bidding process, similar to the [SOE C property development company] block we did before. However, given the parent will be in the deal, he won’t be too sensitive on the bid price. Let’s get ourselves prepared and keep [i]t very confidential at this stage. . . . Please make sure that [Referral Hire C] is invited to the working team.”49.    Credit Suisse HK senior managers exaggerated Referral Hire C’s contributions to the firm. On or about May 18, 2009, Employee D emailed Referral Hire C: “We just did the block [trade] for [a subsidiary of SOE C]. You’ll be nominated in the deal team pls give [Official C] a call to congratulate him and thank him for the mandate.” Referral Hire C later replied, “[A]s I know, almost all banks want to have this deal, including [three competitor banks of Credit Suisse]…But [a subsidiary of SOE C] decided to give CS si[n]ce [Official C] made lots of efforts on this.”

50.    The next day, on or about May 19, 2009, Credit Suisse acted as a bookrunner on a secondary offering for the subsidiary company associated with SOE C valued at over 500 million dollars, earning fees of approximately $6,787,128. On or about June 30, 2009, Referral Hire C received a bonus of approximately $40,000.51.    On or about June 15, 2010, a Credit Suisse banker emailed various senior banking employees to provide an update on the pending and future deals. The banker wrote that a senior official of [SOE C] “recently obtained greenlight from [Official C] regarding asset injection.” Employee D then directed an employee to “leverage [Referral Hire C] on all [SOE C] deal flows.”52.    On or about July 27, 2010, Credit Suisse learned that a SOE C affiliate had awarded mandates related to a bond deal worth several hundred million dollars to two Credit Suisse competitors. On or about July 28, 2010, Employee D referenced the deal and wrote: “It was [Referral Hire C] who made the last minute breakthrough and got us a role around 6pm last night.” This deal earned Credit Suisse $222,899. Referral Hire C’s bonus for 2010 was over $320,000.53.    Or about May 16, 2011, Employee A emailed others that two managing directors wanted to cover SOE C more proactively. Employee A noted steps a select group of Credit Suisse managers had acted to increase Referral Hire C’s compensation (without informing their colleagues), writing “we matched [Referral Hire C]’s bump-up and guarantee. [Referral Hire C’s] major contribution to the firm will be on this account. How can we push [Referral Hire C] harder to pursue this account?” Employee C then replied privately to Employee A that the other senior managers “don’t know about what we did with [Referral Hire C]. Only [Employee D], you and me plus H.R.” During Referral Hire C’s employment with Credit Suisse, Referral Hire C was paid approximately $1.5 million in total compensation. During that same period, Credit Suisse was mandated on five SOE C deals, earning over $29 million dollars.

Hiring and Advancement of Referral Hire to Secure Client Relationship with SOE

54.    During or around June 2010, Credit Suisse hired Referral Hire D as a referral hire from a large energy-related SOE (“SOE D”) in order to obtain business from SOE D. Referral Hire D’s employment was arranged by Credit Suisse during the summer of 2010, with Employee C, and Referral Hire D was to start as an Associate with a promotion to Vice President that same year.55.    Referral Hire D started work at Credit Suisse on or about November 8, 2010. Threedays later, Credit Suisse was awarded a mandate to act “as a joint bookrunner in [a SOE D affiliate]’s IPO” on or about November 11, 2010. Several weeks later, Credit Suisse booked approximately $986,439 in revenue as the deal closed.56.    In a November 16, 2010 email related to the SOE D deal, Employee A relayed that when Employee A had asked a high-ranking executive of SOE D to “push for our incentive,” the high-ranking executive “reminded [Employee A] that we need to pay [SOE D’s] relationship hire — [Referral Hire D], the Associate well at the year end bonus.” One day earlier, Employee A had told Employee B that Referral Hire D was not up for a promotion to Vice President. After the discussion with the high-ranking executive at SOE D, Employee A advocated for Referral Hire D’s promotion, which became official less than two months after Referral Hire D began working at Credit Suisse. Referral Hire D was promoted and consequently became eligible for a bonus. In an earlier email exchange between Employee B and Credit Suisse employees in London and New York concerning the promotion for Referral Hire D, a London employee noted that the promotion request was “abnormal.”

61.    Credit Suisse HK has entered into a non-prosecution agreement with the Department of Justice that acknowledges responsibility for criminal conduct relating to certain findings in the Order.

 

Paul Morjanoff

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