FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor
Episode 59-the Esquenazi Decision on Instrumentalities Under the FCPA
On October 6, 2014, the United States Supreme Court declined to accept an appeal involving violations of the Foreign Corrupt Practices Act (“FCPA”)—the U.S. statute that criminalizes the bribing of foreign officials. The...more
Federal appellate court decisions interpreting the Foreign Corrupt Practices Act (FCPA) are rare. Very rare. Indeed, in the statute’s 36-year history there have been barely more than a handful of appellate court decisions...more
The 11th Circuit US Court of Appeals handed the Department of Justice a clear victory in the Esquenazi appeal. Esquenazi was sentenced to 15 years in jail for FCPA violations – the longest criminal sentenced imposed in a...more
On May 16, 2014, the Eleventh Circuit issued its decision in United States v. Esquenazi, an important ruling that provides guidance as to what types of foreign entities may constitute “instrumentalities” of a foreign...more