What is the current state of the law on bribery?

⁸ See also United States v. Kemp , 500 F.3d 257, 26770, 281 (3d Cir. 2007) (approving of charge in honest services fraud prosecution explaining that, where multiple benefits are given by a person to a public official, "it need not be shown that any specific benefit was given in exchange for a specific official act," so long as payments were made "in implicit exchange for one or more official acts " (emphasis added)); United States v. Jennings, 160 F.3d 1006, 1014 (4th Cir. 1998) ("Bribery requires the intent to effect an exchange of money (or gifts) for specific official action (or inaction), but each payment need not be correlated with a specific official act. Rather, it is sufficient to show that the payor intended for each payment to induce the official to adopt a specific course of action .... Thus, all that must be shown is that payments were made with the intent of securing a specific type of official action or favor in return." (emphases added and citation omitted)).