White Collar
Although honest services wire fraud requires a bribery element under Skilling, the transaction need not be an explicit quid pro quo.
Personal monetary judgments are a legitimate form of forfeiture.
http://www.ca5.uscourts.gov/opinions/pub/14/14-30841-CR0.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.