JPMorgan’s Fruitful Ties to a Member of China’s Elite

It is not known whether Ms. Wen’s father, Wen Jiabao, played any role in that deal. But as prime minister, he would have had ultimate responsibility for state-owned companies and their regulators.

Efforts to reach Ms. Wen and other members of her family were unsuccessful.

A spokesman for JPMorgan declined to comment. In a previous regulatory filing, the bank disclosed that authorities were examining “its business relationships with certain related clients in the Asia Pacific region and its engagement of consultants.”

Executives at JPMorgan’s headquarters in New York did not appear to be involved in retaining Fullmark, a decision that seemed to have fallen to executives in Hong Kong. And the documents reviewed by The Times do not identify a concrete link between the bank’s decision to hire children of Chinese officials and its ability to secure coveted business deals, a connection that authorities would probably need to demonstrate that the bank violated anti-bribery laws.

The Securities and Exchange Commission and the United States attorney’s office in Brooklyn, which are leading the investigation, both declined to comment on the case.

Underpinning their investigation is the Foreign Corrupt Practices Act, which effectively bars United States companies from giving “anything of value” to foreign officials to obtain “an improper advantage” in retaining business. In recent years, the S.E.C. and the Justice Department have stepped up their enforcement of the 1977 law, which is violated if a company acts with “corrupt” intent, or with an expectation of offering a job in exchange for government business.

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