In 2016, to resolve claims that it had engaged in widespread bribery to win mining rights in Africa, OZ Africa Management GP, LLC (OZ Africa) pleaded guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act (FCPA). Prior to sentencing, a group of shareholders of one of the companies affected by that bribery claimed that they were victims of OZ Africa’s misconduct and sought restitution under the Mandatory Victims Restitution Act (MVRA). The U.S. District Court for the Eastern District of New York (Court) recently issued a memorandum and order confirming that the shareholders qualify as victims under the MVRA and are entitled to restitution, but reserving judgment on the amount of restitution. This article discusses the factual and procedural background of the dispute and the Court’s reasoning as to the restitution issue. For an overview of the FCPA, see “WilmerHale Attorneys Discuss FCPA Concerns for Private Fund Managers (Part One of Two)” (May 28, 2015); and “Expert Panel Underscores Heightened Foreign Corrupt Practice Act Enforcement Risk Facing Hedge Fund and Other Private Fund Managers” (Dec. 19, 2013).