Shareholders affected by Och‑Ziff’s foreign bribery scheme to win mining rights in Africa qualify as victims under the Mandatory Victims Restitution Act, a federal court in New York recently held, demonstrating one type of collateral consequence of an FCPA violation. We examine the facts and the decision. See “Och-Ziff’s Settlement Offers Five Compliance Lessons for Hedge Fund Managers and Private Equity Investors” (Nov. 9, 2016).
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