On July 6, 2017, in R v Karigar (2017 ONCA 576), the Ontario
Court of Appeal upheld a decision under Canada's anti-bribery
legislation in which Nazir Karigar, a Canadian citizen, was
convicted of agreeing to bribe a foreign public official.
The trial decision regarding Mr. Karigar received widespread
attention as it was the first conviction of an individual under the
Corruption of Foreign Public Officials Act (the CFPOA). The lower
court convicted Mr. Karigar for a scheme to bribe Indian officials
in return for a contract. There was no proof that any officials
actually participated in the scheme, and Indian officials never
awarded a contract to the company for whom Mr. Karigar acted. The
Court of Appeal upheld the lower court finding that Mr.
Karigar's "agreement" with representatives of the
Canadian company to offer bribes was enough for a conviction under
the CFPOA. The sentence of three years in prison was upheld.