Today’s post is from Mike Dearington, an associate at Arent Fox LLP in Washington, D.C. Dearington previously authored several FCPA Professor guest posts as a law student regarding the prosecution of corrupt foreign officials. (see here, here, here, here, and here).
In recent years, the Department of Justice has ratcheted up its efforts to pursue corrupt foreign officials who accept bribes in return for improper business advantages. By my count, since 2009 alone, federal prosecutors have charged at least eleven foreign officials with crimes related to bribery schemes, netting numerous guilty pleas and convictions. These prosecutions appear to be part of DOJ’s broader strategy of targeting the “demand side” of foreign bribery, rather than focusing only on bribe-payers.