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From The Docket – A Rare Restitution Order

Judicial Decision

I recently spent some time in the court dockets for individuals charged with Foreign Corrupt Practices Act offenses and discovered some interesting tidbits. Next week, these pages will highlight a motion to dismiss currently pending that generally escaped public attention.

In the meantime, this post concerns a rare restitution order issued in an individual FCPA enforcement requiring the defendant to pay $500,000 to a “victim.”

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Bahn, Et Al – Not A Typical FCPA Enforcement Action


Last week the DOJ announced Foreign Corrupt Practices Act, and related charges, against four individuals for their roles in a scheme to pay $2.5 million in bribes to facilitate the $800 million sale of a commercial building in Vietnam (the so-called Landmark 72 pictured at left) to a Middle Eastern sovereign wealth fund.

It certainly was not a typical FCPA enforcement action.

In fact it was downright strange in that the bribery scheme was unsuccessful and the third party intended to facilitate the bribery scheme simply pocketed the money for himself.

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