As highlighted in this 2018 post, in the aftermath of the 2016 Och-Ziff Foreign Corrupt Practices Act enforcement action (see here and here for prior posts) former shareholders of Canadian mining company Africo Resources Ltd. ("Claimants") sough restitution pursuant to the Mandatory Victims Restitution Act for losses allegedly incurred as a result of Och-Ziff's bribery of corrupt officials in the Democratic Republic of the Congo. The DOJ opposed the request arguing, among other things, that Claimants had not show direct or proximate causation of quantifable harm from Och-Ziff's conduct and that damages were too speculative. However, as highlighted here, in August 2019 the court rejected the DOJ's position and found that Claimants are victims of Och-Ziff's crime under the MVRA and "directed the parties to submit supplemental briefing regarding how to calculate the appropriate restitution amount."