Welcome back to the podcast, bribes,windle, or steel. I'm Alexandra Ragi, and today we're

reviewing another landmark FCPA case, this one from 2016. My guest is Jeffrey Clark, a partner

in the litigation department and a member of the compliance investigations

and enforcement practice group in the Washington office of Wilkie Farr and Gallagher. Jeff's practice

includes conducting complex, worldwide internal corporate investigations and providing advice to corporate

management and directors regarding compliance and enforcement matters. He also has substantial

experience in other types of international business and white-collar litigation.

Jeff is a longtime friend of Trace.

He's served on our board, and Wilkie Far has been our partner firm for over a decade, Jeff.

Thank you for joining me.

Thank you, Alexandra.

It's great to be here with you.

On the podcast, we're reviewing a number of cases that have

different lessons learned, are unique in some way. And today we're going to cover OXIF Capital Management Group.

Why don't you just launch in and tell us about the case? The OXIF case is interesting for a number of reasons,

really. And for those who are not familiar with

AXIF, it's a hedge fund. It's a publicly traded, one of the largest alternative investment

asset managers around, traded on the New York Stock Exchange with $30 billion of assets under

management. And the OXF FCPA case is interesting, first of all, because it was

really the DOJ and SEC's first foray against a significant hedge fund or investment manager. And you can

imagine that if that's a trend that were to continue, there's a lot of invested money around the

world that would

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