Welcome back to the podcast, bribe, swindler, steel. I'm Alexandra Rogi, and today we're

talking about the Arapakota decision, the first bribery acquittal under the Canadian CFPOA,

the Corruption of Foreign Public Officials Act. My guest is Jessica Warwick. Jessica is a litigator with Norton Rose Fulbright in Ottawa.

She conducts internal investigations and advises on compliance with the CFPOA.

Jessica, thank you for joining me.

Thank you so much for having me.

For those unfamiliar with this case, can you just start with a broad overview of the facts?

Mr. Arapicota was the founder and former CEO of a software company called IMEX Systems.

After he left the company, IMEX's new management conducted an internal investigation to his

expenses. And through that process, they found some expenses of interest and

contacted the Canadian authorities, the RCMP, to report concerns about a trip to the U.S.

that Mr. Aipakota had purchased for a Botswanan public official who was named Dr. Carotelan's

way and his family.

The trip allegedly cost in the ballpark of $40,000 U.S., which included airfare, accommodations,

shopping, dinners, and attractions.

The RCMP charged Mr. Eric Cotto with one count of bribery of a foreign public official

under Canada's international

anti-corruption statute, which is called the Corruption of Foreign Public Officials Act,

or the CFPOA for short. And the theory of the prosecutor's case was essentially that Mr.

Arapakota gave Dr. Caroteletsway this trip in exchange for three letters, confirming that

Botswana had intended to engage IMEX on a project. So the prosecutor alleged that Mr. Arapakota

believed that these three letters would benefit his company's business dealings. And that's the

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