An "Understanding" Enough for Bribery Conviction

The most recent issue of the Federal Law Enforcement Training Center's newsletter, The Informer, summarizes U.S. v. Ganim, a case interpreting the quid pro quo element of the bribery statute:

The specific intent element (quid pro quo / this for that) for bribery, extortion, and honest services mail fraud crimes may be satisfied by showing that a government official received a benefit in exchange for his promise to perform specific official acts or to perform such acts as the opportunities arise. It is sufficient if the defendant understood he was expected as a result of the payment to exercise particular kinds of influence on behalf of the payor as specific opportunities arose.