News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Agency Relationship

Polsinelli

District Court Sets Parameters of Agency Liability for Foreign Nationals in FCPA Prosecutions

Polsinelli on

Recently, the United States District Court for the District of Connecticut issued its order in United States v. Hoskins, vacating a jury’s November 2019 conviction of a foreign entity’s executive for violating the Foreign...more

Eversheds Sutherland (US) LLP

Hoskins escapes FCPA convictions while money laundering convictions remain

On February 26, 2020, the US District Court for the District of Connecticut reinforced the Second Circuit’s recent decision to limit prosecutors’ ability to pursue Foreign Corrupt Practices Act (FCPA) charges against foreign...more

WilmerHale

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

WilmerHale on

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

Snell & Wilmer

District Court Issues Key Ruling on FCPA Definition of “Agent” for Purposes of Foreign Nationals

Snell & Wilmer on

On February 26, a federal district court in Connecticut acquitted the defendant in United States v. Hoskins on all counts related to the Foreign Corrupt Practices Act (“FCPA”). A jury had previously found the defendant guilty...more

A&O Shearman

Judge Grants Post-Trial Acquittal On FCPA Counts

A&O Shearman on

On February 26, 2020, a federal judge in Connecticut granted, in part, defendant Lawrence Hoskins’s post-trial motion for acquittal on seven counts relating to violations of the Foreign Corrupt Practices Act. United States v....more

Dorsey & Whitney LLP

UPDATE: Trial Court Overturns Former Alstom Executive’s Foreign Corrupt Practices Act Convictions

Dorsey & Whitney LLP on

Former Alstom SA executive Lawrence Hoskins’s jury convictions under the Foreign Corrupt Practices Act (“FCPA”) were set aside on February 26, 2020, by Judge Janet Bond Arterton of the United States District Court for the...more

BCLP

Judge Overturns FCPA Conviction on Lack of Evidence of Agency

BCLP on

In a closely followed case, on February 26, 2020, a District Court Judge in Connecticut granted Lawrence Hoskins’ motion for acquittal on the seven FCPA counts on which the jury convicted him. Hoskins was a UK citizen who...more

Cozen O'Connor

Court Reverses Foreign National’s FCPA Conviction, Setting a High Bar to Establish an Agency Relationship

Cozen O'Connor on

A ruling issued on Wednesday, February 26 by a Connecticut federal court details the type of control necessary to find that a foreign national acted as an agent of a U.S. domestic concern for purposes of falling within the...more

Dorsey & Whitney LLP

Former Alstom Executive Convicted of Foreign Corrupt Practices Act Charges on Agency Theory

Dorsey & Whitney LLP on

Lawrence Hoskins, a British citizen and former employee of French conglomerate Alstom SA, has been found guilty by a federal jury in Connecticut of 11 of 12 criminal charges, including six counts of violating the United...more

Morgan Lewis

No FCPA Accomplice Liability for Non-resident Foreign Nationals if No Agency

Morgan Lewis on

Court rules that the US Department of Justice cannot expand the FCPA’s reach simply by charging non-resident foreign nationals with conspiracy....more

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