The U.S. Securities and Exchange Commission (“SEC”) on May 20, 2015 announced a settlement with global resources company BHP Billiton over allegations that BHP Billiton violated the Foreign Corrupt Practices Act (“FCPA”) by providing luxury travel packages to foreign government officials and their spouses at the 2008 Beijing Olympic Games. The settlement, imposed through a Cease-and-Desist Order (“Order”), underscores the importance of adequate safeguards and internal controls when providing hospitality to foreign government officials.
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