Oil-For-Food, Iraq: Grist For The Anti-Corruption Mill

Law360, New York (March 21, 2008, 12:00 AM EDT) -- In recent months the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have continued to bring enforcement actions and seek substantial fines against companies accused of making improper payments in the course of their involvement with the United Nations’ Oil-for-Food Program (“OFFP”) and the Government of Iraq.

Among other things, these actions illustrate the utility of the accounting provisions of the FCPA in reaching payments that fall outside the scope of the Act’s anti-bribery provisions, but violate other laws, such as OFAC-administered sanctions...
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