Jury Acquits Orrick Client on All Charges in “Africa Sting” – the Largest Foreign Bribery Prosecution in History


Following a 66-day jury trial in U.S. District Court for the District of Columbia, U.S. District Judge Richard J. Leon entered judgment yesterday acquitting Orrick client Greg Godsey on all counts of alleged violations of the Foreign Corrupt Practices Act (“FCPA”). Orrick Partner Michael J. Madigan represented Mr. Godsey at trial.
The allegations against Mr. Godsey stemmed from a lengthy undercover “sting” operation conducted by the Fraud Section of the U.S. Department of Justice (“DOJ”) and the Federal Bureau of Investigation (“FBI”).  Prosecutors indicted 22 military and law enforcement equipment industry executives in the "sting" scenario supposedly involving a proposed sale of military equipment to the Government of Gabon.

In fact, the real Minister of Defense was not involved and no procurement of equipment was to take place.  Instead, the FBI entered into a partnership with Richard Bistrong, a convicted briber and embezzler, to create a fake scenario in which a $1.5 million bribe was to be offered in connection with a purported $15 million contract. 
“Justice has been done,“ said Mr. Madigan, adding: “Greg should never have been charged.  This ill-advised Sting was not an honest one but nothing short of a "Game of Gotcha" which cost Greg two years of his life.  Today, he finally has his life back and is very grateful for the jury’s verdict.”
This was the first time the U.S. government has used a large-scale sting operation in a foreign-bribery probe.  The government indicted the defendants on December 11, 2009, and had touted the case as a “turning point” in FCPA enforcement.  Hopefully today's verdict will be just that.