In 2016, Och‑Ziff Capital Management (Och‑Ziff) and two of its executives entered into a settlement with the SEC and DOJ arising out of their alleged violations of the Foreign Corrupt Practices Act (FCPA) when pursuing investment opportunities in Africa. The fallout from that FCPA probe continues. A grand jury in the U.S. District Court for the Eastern District of New York recently returned an indictment against Michael L. Cohen, a former senior executive at Och‑Ziff. The indictment charges Cohen with multiple counts of investment adviser fraud, wire fraud, obstruction of justice and conspiracy based on alleged misrepresentations he made to an investor about conflicts of interest when seeking the investor’s consent to a transaction. In a press release announcing the unsealing of the indictment, federal prosecutors and representatives from the Internal Revenue Service and Federal Bureau of Investigation reiterated their commitment to holding accountable individuals who commit fraud, violate the public trust, breach fiduciary duties or engage in other corrupt activities. The indictment, therefore, is another reminder that fund managers must be scrupulous in identifying and managing conflicts of interest, which remain a perennial enforcement priority. This article summarizes the substantive allegations in the indictment. For coverage of the Och‑Ziff FCPA settlement, see “Recent SEC and DOJ Settlements With Och‑Ziff and Two Executives Underscore FCPA Compliance Risks to Private Fund Managers” (Oct. 27, 2016). For coverage of the SEC FCPA enforcement action against Cohen, see “SEC Brings Enforcement Action for FCPA Violations Against Two Och‑Ziff Employees” (Feb. 16, 2017).