As a result of a routine audit, Japan's Securities and Exchange Surveillance Commission (SESC) has begun an inquiry into whether employees of the bank breached rules when they entertained Japanese pension fund executives. Pension fund staff are covered by state anti-bribery rules as part of their work involves dealing with the national pension scheme. 

Don't dine at the same table

Tomoki Debari, a partner in Anderson Mori & Tomotsune and an expert on the anti-bribery rules, told The Age: 'My advice would be you shouldn't dine together at the same table. Unless you split the bills.' However, the bank had itself begun investigating the matter before it was picked up in May by the SESC audit. It has stopped marketing directly to pension funds since then. These facts could be mitigating factors if the SESC is considering public sanctions.