A Conversation with Richard Bistrong: FCPA Violator and Undercover Cooperator

9 Pages Posted: 12 Apr 2014

See all articles by Mike Koehler

Mike Koehler

Southern Illinois University School of Law

Date Written: April 10, 2014


Richard Bistrong. Most people likely associate his name with the manufactured Africa Sting Foreign Corrupt Practices Act enforcement action. The Africa Sting action involved a purported deal to purchase equipment for the presidential guard of an African Government with FBI agents posing as African Government officials and Bistrong working as an undercover informant.

The Africa Sting enforcement action resulted in criminal charges against 22 individuals. After extensive motions practice and two trials, all charges against all defendants were ultimately dismissed by the DOJ and the action ended with a federal judge calling the entire case a “long and sad chapter in the annals of white collar criminal enforcement.”

Bistrong was not charged in the Africa Sting case, but previously pleaded guilty to “real-world” FCPA conduct, including conspiring with others to bribe United Nations officials, Dutch officials, and Nigeria officials. This charge stemmed from Bistrong’s work as the international sales vice president for a large, successful and publicly traded multi-national corporation. Bistrong started to cooperate with the DOJ in June 2007 and the judge ultimately credited Bistrong’s extensive cooperation at sentencing.

At the time of this Q&A, Bistrong is out of prison but still serving the supervised release portion of his sentence. In this detailed Q&A, Bistrong describes: the circumstances that put him in a position to violate the FCPA; what made him think he could get away with it; his thought process when he realized he was caught; and how he spent his time in federal prison. In the Q&A, Bistrong not only looks back, but forward as well, and shares what he learned from his experience and what he hopes to accomplish in the future.

Keywords: FCPA, Foreign Corrupt Practices Act

Suggested Citation

Koehler, Mike, A Conversation with Richard Bistrong: FCPA Violator and Undercover Cooperator (April 10, 2014). Available at SSRN: https://ssrn.com/abstract=2423654 or http://dx.doi.org/10.2139/ssrn.2423654

Mike Koehler (Contact Author)

Southern Illinois University School of Law ( email )

1150 Douglas Drive
Carbondale, IL 62901-6804
United States

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