In the wake of the SEC’s September 2016 settlements with Daniel S. Och, Joel M. Frank, Och-Ziff Capital Management LLC (OZ) and OZ Management LP, the SEC has taken aim at two additional OZ employees – senior executive Michael L. Cohen and analyst Vanja Baros. In a complaint filed in the U.S. District Court for the Eastern District of New York, the SEC asserts that, by arranging to pay bribes to numerous government officials in Africa to secure lucrative deals for OZ funds and misleading an OZ investor in the process, Cohen and Baros violated the Foreign Corrupt Practices Act, anti-fraud provisions of the Investment Advisers Act of 1940 and certain provisions of the Securities Exchange Act of 1934. For our full coverage of the OZ settlement, see “Five Compliance Lessons Private Fund Managers Can Glean From Och-Ziff’s FCPA Settlement” (Nov. 3, 2016); and “Recent SEC and DOJ Settlements With Och-Ziff and Two Executives Underscore FCPA Compliance Risks to Private Fund Managers” (Oct. 27, 2016).