The Bank of New York Mellon Corporation agreed to pay sanctions of almost US $15 million to resolve allegations by the Securities and Exchange Commission that its retention of three interns during 2010 and 2011 constituted violations of the anti-bribery and internal accounting control provisions of the Foreign Corrupt Practices Act. The SEC claimed that, in order to maintain and expand business with an unidentified Middle Eastern sovereign wealth fund, BNY agreed to retain three family members of two government officials who were both senior officials affiliated with the sovereign wealth fund. None of the interns, claimed the SEC, met the “rigorous criteria” of the internship program ordinarily administered by BNY. BNY violated relevant law, claimed the SEC, by “providing valuable internships to relatives of foreign officials … to assist [it] in retaining and obtaining business,” and by not having a system of internal accounting controls “sufficient to provide reasonable assurance that its employees were not bribing foreign officials.” One of the interns was unpaid. To resolve this matter, BNY agreed to pay a fine of US $5 million, disgorgement of US $8.3 million, and pre-judgment interest of US $1.5 million.