Adding to the list of creative ways to accomplish bribery, the SEC’s recent settlement with BNY demonstrated that, at least in the SEC’s opinion, a job can be a “thing of value” that can lead to an FCPA violation. The government made it clear that to avoid such violations, any robust anti-corruption program must integrate policies about hiring practices. Going forward, companies can use the settlement documents as a helpful roadmap for updating their compliance program to meet the SEC’s maturing expectations. The Anti-Corruption Report spoke to a number of experts in the field (including the chief compliance officer of a multinational company) who together identified three key aspects of a hiring policy and discussed how companies should be updating their training program. In the first article in this two-article series, we considered the expansion of FCPA liability and its broader implications for FCPA enforcement. See “BNY Mellon Settles Nepotism-Related Charges for $14.8 Million” (Aug. 19, 2015).