BHP Billiton took its sponsorship of the 2008 Beijing Olympics a step too far, the SEC alleged in an administrative order resolving FCPA charges with the Australian mining giant.  The SEC announced on May 20, 2015 that BHP Billiton entities (BHPB) agreed to pay $25 million to settle charges that in 2008, despite a screening process for invitees to the Olympics designed to mitigate bribery risk, it provided luxury travel and hospitality for foreign government officials from whom it sought business.  The SEC cites five failures of BHPB’s program in its Order, demonstrating how the tension between the marketing and compliance departments can result in compliance programs that may look effective on paper but do not hold up on the ground.  See also “Nine Steps to Reduce Corruption Risk When Entertaining Clients at the 2014 Winter Olympics and Beyond” (Feb. 5, 2014).