In the wake of the SEC’s September 2016 settlements with Daniel S. Och, Joel M. Frank, Och-Ziff Capital Management LLC (OZ) and OZ Management LP, the SEC has taken aim at two additional OZ employees – senior executive Michael L. Cohen and analyst Vanja Baros. In a Complaint filed in the U.S. District Court for the Eastern District of New York, the SEC alleges that Cohen and Baros arranged to pay tens of millions of dollars in bribes to numerous government officials in Africa to secure lucrative deals for OZ funds and misled an OZ investor in the process. For our full coverage of the OZ settlement, see “Och-Ziff’s Settlement Offers Five Compliance Lessons for Hedge Fund Managers and Private Equity Investors” (Nov. 9, 2016); and “Dirty Dealings in Africa Result in SEC and DOJ Settlements for Och-Ziff and Two Executives” (Oct. 26, 2016).