In August 2015, the Securities and Exchange Commission (US) imposed a fine of USD 14.8 million on The Bank of New York Mellon Corporation (BNY Mellon) in order to settle charges alleging violation of the Foreign Corrupt Practices Act (FCPA). According to the SEC, BNY Mellon violated the FCPA when it hired relatives of foreign government officials as interns in exchange for doing business with a foreign wealth fund. The SEC’s argument was that BNY Mellon did not follow their usual internal guidelines for hiring interns, such as evaluating and hiring the interns through BNY Mellon’s established internship program, interviewing the interns and doing a legal and compliance background check of potential violations prior to hiring them. This recent action is part of an increasing trend by the SEC to pursue alleged violations and impose fines not only on individuals and U.S. companies but also on their foreign subsidiaries as well as third party partners and intermediaries engaged by such companies.