Most people are familiar with the Foreign Corrupt Practices Act, which makes it a crime for U.S. citizens and residents, employees of U.S. companies, or anyone physically present in the United States to obtain or retain business abroad by paying bribes to foreign officials.

For years, the FCPA has been one of federal prosecutors’ favorite tools to prosecute foreign bribery.  But the FCPA criminalizes the payment of a bribe, not the receipt of a bribe.  And while U.S. prosecutors have charged the corrupt foreign officials who demand and receive bribes, those prosecutions mostly have relied on obscure money laundering and money-laundering conspiracy theories.