Also in late October, a federal judge sentenced Bobby Jay Elkin Jr. to three years' probation and a $5,000 fine. In August, Elkin had pleaded guilty to violating the FCPA by making $3 million in payments to officials in Kyrgyzstan during the years he spent there as a manager for Dimon Inc. Dimon describes itself as a tobacco merchant.

The sentence was much less than the five-year minimum prison term recommended by federal sentencing guidelines or the 38 months suggested by the prosecutor. The judge explained his leniency by citing the CIA's routine bribing of Afghan warlords. In addition, the judge noted the detailed help Elkin gave to investigators.

Elkin's punishment is part of a bribery investigation into the company that now owns Dimon, Alliance One International Inc., a Morrisville, N.C., tobacco merchant with 2010 sales of $2.3 billion. Alliance One Osh, the company's Kyrgyzstan operation, and Alliance One International, were sentenced by the judge to pay $9.45 million in fines in connection with earlier guilty pleas. Alliance One also settled SEC complaints by paying $10 million.

A DOJ senior trial attorney who prosecuted the case said Elkin did not try to avoid responsibility, and made the government’s case against two branches of Alliance One.