A recent post on FCPA Professor questions why FCPA fines and penalties go directly into the U.S. Treasury instead of being shared with victims. “Why are there generally no efforts to identify the victims of FCPA violations and to allow those victims to pursue legal remedies?” the article says. “The U.S. government actually identified certain victims of Och-Ziff’s bribery schemes, but later backed off this determination perhaps because it complicated the DOJ’s efforts to resolve the matter.”
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Former Equity Holders of Africo Resources Seek Designation As “Victims” of Och-Ziff’s Bribery Schemes and Raise Concerns About the Underlying Settlement
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