For two decades, federal prosecutors have aggressively prosecuted companies and executives that pay bribes to win business overseas, most often through use of the Foreign Corrupt Practices Act, an antibribery law passed in 1977. But rarely have they sought to identify specific victims of corruption.
That’s starting to change. After a surprise appearance by aggrieved investors in a bribery case involving the hedge fund Och-Ziff Capital Management Group LLC prosecutors and companies like Credit Suisse are paying closer attention to the possibility of restitution claims made by victims when negotiating settlements over criminal wrongdoing.
‘Enforcement 40’ for 2020
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