In 2016, the question of what was meant by the term in the FCPA “anything of value” was soundly settled. From the February VimpelCom resolution to the “Sons and Daughters” hiring cases of Qualcomm and JPMorgan Chase, regulators pushed the meaning of the term “anything of value” to literally just that: “anything.” In VimpelCom, the SEC alleged that the company violated the FCPA’s anti-bribery provisions by donating approximately $500,000 to the foreign official’s charities, even if none of the money benefited the foreign official ,who otherwise received remuneration. There was no evidence, however, this benefited the foreign official involved.
