"SEC Continues to Tackle FCPA Violations"

9/1/15: The Securities and Exchange Commission isn’t fooling around with its enforcement of the FCPA. In the process, it’s also reminding compliance officers of the various ways they can run afoul of the law. Recently, the SEC announced a settlement with BNY Mellon to settle charges that it violated the FCPA by providing...student internships to family members of foreign government officials associated with a Middle Eastern sovereign wealth fund. According to SEC, the company “… did not evaluate or hire the family members through its existing, highly competitive internship programs that have stringent hiring standards and require a minimum grade point average and multiple interviews.” The case is a good reminder that violating the FCPA doesn’t have to involve exchanging large chunks of cash in exchange for new or continuing business. Sometimes, it’s enough to offer an internship to a family member associated with a foreign government official.