As part of the arrangement, the Libyan fund planned to hand over the $50 million to Palladyne, according to documents reviewed by the Journal. Goldman said it would make the payment if the deal satisfied “Foreign Corrupt Practices Act representations as set out in the Terms Letter,” among other conditions.

Lawyers said firms generally can’t rely on such language to ensure compliance with antibribery laws.

In other words, “we will pay this $50 million bribe to your oil minister’s son-in-law as long as we don’t call it a bribe.”

And Goldman’s supposed to be the smart ones.

Ryan Chittum is a former Wall Street Journal reporter, and deputy editor of The Audit, CJR's business section. If you see notable business journalism, give him a heads-up at