The U.S. Department of Justice (DOJ) recently announced a new approach for the U.S. Foreign Corrupt Practices Act (FCPA). However, the indictments against the former Austrian banker Peter Weinzierl and other foreign bankers in the Odebrecht case are not based on violations of the FCPA. Instead, the DOJ charged Weinzierl and his co-defendant, Alexander Waldstein, with multiple counts of money laundering and related financial crimes under U.S. money laundering statutes