Restitution in FCPA Cases: Who Is a Victim of Foreign Corruption?

A vital part of defending the targets of FCPA investigations is finding a path to a fair and final resolution, and, in the case of a guilty plea, this includes an understanding of the potential for restitution to victims of the foreign corruption. In the last decade, restitution became a significant issue in a number of FCPA cases. In this guest article, Morvillo Abramowitz partner Jonathan Sack and attorney Kefira Wilderman discuss court decisions which address the circumstances under which a defendant convicted of an FCPA violation may be required to pay restitution, which is one of the many potential consequences of a guilty plea in an FCPA prosecution. See “In Latest Chapter of the Och-Ziff FCPA Saga, Court Rules That It Pay Restitution to Victims of Bribery” (Jan. 8, 2020).

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