The SEC claims that between 2007 and continuing through at least August 2012, Baros and Cohen allegedly executed multiple schemes involving corrupt transactions and bribes to high-ranking government officials in several African countries including Libya, Chad, Niger, Guinea, Congo, and the Democratic Republic of the Congo. According to the SEC, Baros began working with Cohen at Och-Ziff in 2007 and participated in multiple corrupt transactions that aimed to secure Och-Ziff special access to investment opportunities in Africa, obtain or retain business for the hedge fund or its subsidiaries, and financially benefit themselves in the process.
To facilitate the various schemes, Cohen and Baros, acting on behalf of Och-Ziff, allegedly engaged the services of multiple agents, intermediaries, and business partners who promoted themselves as having connections to high-ranking foreign government officials and, according to the SEC, typically had reputations for engaging in unsavory business practices. Baros and Cohen later allegedly funneled tens of millions of dollars (often from Och-Ziff investor accounts) to those agents, intermediaries, and business partners, knowing that at least of portion of those monies would be paid as bribes to government officials.
