The U.S. Department of Justice wasted no time announcing its first Foreign Corrupt Practices Act case of 2015. On Jan. 6, 2015, just two days into the first full week of the new year, Dmitrij Harder, the former owner and president of Chestnut Consulting Group Inc. and Chestnut Consulting Group Co. (generally referred to as the “Chestnut Group”), was indicted by a federal grand jury. Harder was charged with violating the FCPA and Travel Act and participating in a scheme to launder the proceeds of those crimes. This case continues the trend of enforcement actions against individuals. It also involves the rarely used “public international organization” element of the FCPA’s definition of “foreign official.”

The Allegations -

Between 2007 and 2009, Harder allegedly engaged in a scheme to pay approximately $3.5 million in bribes to an official of the European Bank for Reconstruction and Development (“EBRD”) in order to obtain favorable reviews of clients’ financing applications.

Originally published in Law360 on January 30, 2015.