On September 29, 2016, the U.S. Securities and Exchange Commission (SEC) announced [3] that “Och-Ziff Capital Management Group has agreed to pay nearly $200 million to the SEC to settle civil charges of violating the Foreign Corrupt Practices Act (FCPA).” In a parallel proceeding, Och-Ziff settled [4] with the U.S. Department of Justice (DoJ) and “agreed to pay a criminal penalty of more than $213 million in connection with a widespread scheme involving the bribery of officials in the Democratic Republic of Congo (DRC) and Libya.” Between the two proceedings, Och-Ziff will pay approximately $412 million in criminal and regulatory penalties.  According to the SEC’s Director of Enforcement, “Och-Ziff engaged in complicated, far-reaching schemes to get special access and secure significant deals and profits through corruption.” A U.S. attorney working on the DoJ proceeding stated that “[d]espite knowing that bribes were being paid to senior government officials, Och-Ziff repeatedly funded corrupt transactions.” According to reports [5], this case fits within a trend of various federal agencies prosecuting high profile fraud cases after the 2008 financial crisis.