In a decision with implications for the extraterritorial reach of the Foreign Corrupt Practices Act (FCPA), the U.S. Court of Appeals for the Second Circuit held in United States v. Hoskins that a person may not “be guilty as...more
9/4/2018
/ Aiding and Abetting ,
Appeals ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Extraterritoriality Rules ,
Foreign Corrupt Practices Act (FCPA) ,
Non U.S. Person ,
Physical Presence Test ,
Securities and Exchange Commission (SEC)
In a decision that has implications for non-U.S. financial institutions with correspondent accounts in New York, a closely divided New York Court of Appeals held on November 22, 2016, that the “[r]epeated, deliberate use [of...more