The variety of charges recently brought by the US Department of Justice's (DOJ) Foreign Corrupt Practices Act (FCPA) Unit against former Bechtel executive Asem Elgawhary signals that the DOJ is not only pursuing improper payments to foreign officials, but also company executives who solicit and accept improper payments. It also demonstrates the Unit's inclination to look for other crimes to charge when FCPA violations are unavailable. Bechtel was not charged, and the indictment details how Elgawhary evaded Bechtel’s controls.
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