As has been widely reported, various countries have frozen (or have been asked to freeze) the assets of former President Hosni Mubarak and other former top officials. See here for Samuel Rubenfeld’s roundup at Wall Street Journal Corruption Currents.
Were any of the billions or millions of Mubarak’s assets, or those of other former top officials, obtained because of Foreign Corrupt Practices Act violations?
That is the question posed by a reader who notes that corruption investigations generally follow regime change.
During Mubarak’s regime, several FCPA enforcement actions alleged conduct involving (in whole or in part) Egypt such as Lockheed, Metcalf & Eddy, Textron, United Industrial Corporation, York, and Daimler.
It is one thing to allege conduct implicating low-ranking “foreign officials” or employees of state-owned or state-controlled entities.
It is quite another to investigate conduct involving top officials of a government generally viewed as an ally in a volatile area of the world. Such barriers would seem to be removed with Mubarak’s ouster and an investigation may now even be viewed as a way to further U.S. relations with a new Egyptian government.
The reader asks, will Mubarak’s removal result in FCPA floodgates being opened in Egypt?
The past few years have witnessed certain “industry sweeps.” Will a “country sweep” be next?