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FCPA Litigation Update: DOJ Theories on Unit of Prosecution and Agency Tested, to Mixed Results

Two recent rulings in separate foreign bribery cases highlight the continued impact of individual prosecutions on the interpretation of various provisions of the Foreign Corrupt Practices Act (FCPA). In United States v....more

Second Circuit Limits Government's Ability to Prosecute Foreign Persons and Companies for Conspiracy to Violate the FCPA

On August 24, 2018, the United States Court of Appeals for the Second Circuit issued a significant ruling regarding the reach of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign companies and individuals in United...more

Federal Judge Rejects DOJ’s Theory of FCPA Accomplice Liability

On August 13, 2015, a US district judge dismissed a charge seeking to hold a defendant criminally liable for conspiracy to violate the Foreign Corrupt Practices Act (FCPA) if he is not a principal or agent of a US domestic...more

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