The sovereign wealth fund officials requested that BNY Mellon provide their family members with internships, and they made numerous follow-up requests about the status, timing, and other details of the internships for their relatives. BNY Mellon employees viewed the internships as important to keep the sovereign wealth fund's business. "The FCPA prohibits companies from improperly influencing foreign officials with 'anything of value,' and therefore cash payments, gifts, internships, or anything else used in corrupt attempts to win business can expose companies to an SEC enforcement action," said Andrew J. Ceresney, Director of the SEC Enforcement Division. "BNY Mellon deserved significant sanction for providing valuable student internships to family members of foreign officials to influence their actions." The SEC's order finds that BNY Mellon lacked sufficient internal controls to prevent and detect the improper hiring practices.