FCPA Jurisdiction: The Courts Weigh In

Introduction -

The jurisdictional reach of the Foreign Corrupt Practices Act (‘‘FCPA’’) is famously long. U.S. regulators have claimed that the statute applies to U.S. and foreign corporations; U.S. nationals anywhere in the world; foreign nationals anywhere in the world whose conduct directly, and sometimes indirectly, touches U.S. soil; transactions occurring entirely in the U.S.; and transactions whose only contact with the U.S. was the routing of payments through domestic banks.

The FCPA outlaws corporate bribery of foreign officials or third-party intermediaries through its antibribery provisions, which prohibit payments to foreign officials made to attract or retain business. The FCPA’s books and records provisions require accurate accounting and adequate internal accounting controls.

Originally published in the Corporate Accountability Report, 11 CARE 641, 6/14/13, 06/17/2013.

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