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No Accomplice, Conspiracy Liability for Certain Foreign Nationals in FCPA Crimes

In a decision that is likely to resonate across various US government enforcement efforts, the US Court of Appeals for the Second Circuit recently ruled that the Foreign Corrupt Practices Act does not apply to nonresident...more

Federal Appeals Court Defines “Instrumentality” Under FCPA

Federal appeals court provides a two-step “control” and “function” analysis for determining whether an entity qualifies as an “instrumentality” under the Foreign Corrupt Practices Act. On May 16, the U.S. Court of...more

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