The SEC’s investigation, which started in 2009, related to previously terminated minerals exploration and development efforts as well as hospitality provided by BHP at the Olympics as part of its sponsorship, when it invited customers, suppliers, business partners, government officials and employees to the event.

The SEC charged BHP with violating the Foreign Corrupt Practices Act after the investigation found the miner failed to devise and maintain sufficient internal controls over the hospitality program.

BHP invited 176 government officials and employees of state-owned enterprises to attend the Olympics at the company’s expense, who enjoyed hospitality packages that included event tickets, luxury hotel accommodations, and sightseeing excursions valued at $12,000-16,000 per package.

“BHP Billiton footed the bill for foreign government officials to attend the Olympics while they were in a position to help the company with its business or regulatory endeavors,” director of the SEC’s Division of Enforcement Andrew Ceresney said.

“BHP Billiton recognised that inviting government officials to the Olympics created a heightened risk of violating anti-corruption laws, yet the company failed to implement sufficient internal controls to address that heightened risk.”

While BHP will pay the civil penalty, the SEC order makes no findings of corrupt intent or bribery and noted the significant cooperation of the company during the investigation and the remedial actions taken since to enhance compliance.

BHP said it had no independent compliance function at the time, but had since established one that reports to the Risk & Audit Committee of the board.

BHP CEO Andrew Mackenzie said BHP had fully cooperated with the SEC.

“We have taken the appropriate remedial actions and developed a world-class compliance program that builds on the strong policies we have had in place,” he said.

“BHP Billiton operates a global resources business and recognises that the highest standards of business conduct are an essential part of our operations.

“Our company has learned from this experience and is better and stronger as a result.”

As part of the settlement, BHP will report to the SEC for 12 months on its compliance program.

The US Department of Justice has concluded its investigation and will not take action against BHP.

BHP said it would continue to cooperate with the Australian Federal Police investigation, which was announced in 2013.