FCPA charges have been brought for the first time against a broker-dealer. The matter involves former-U.S. broker-dealer Direct Access Partners and the state economic development bank of Venezuela, BANDES. The conduct was discovered during a review of the broker-dealer’s activities by the SEC’s New York office, a review that does not appear to have been focused on corruption issues but was instead a more routine review. Subsequently, the SEC and DOJ charged employees of the broker-dealer with funneling portions of commissions paid in connection with trading activity to an official at the bank in exchange for the official directing trading business to the broker-dealer. The DOJ charged the Venezuelan official with money laundering; the managing director of Direct Access Partners has been charged under the FCPA, the federal Travel Act, federal conspiracy laws, and money laundering, as well as with civil violations of U.S. securities laws. See Press Release, Dep’t of Justice, Managing Partner of U.S. Broker-Dealer Charged in Manhattan Federal Court with Participating in Massive International Bribery Scheme, (June 12, 2013); SEC Release No. 2013-109, SEC Announces More Charges in Massive Kickback Scheme to Secure Business of Venezuelan Bank (June 12, 2013).