INSIGHT: Second Circuit Limits Reach of FCPA

September 27, 2018

In an important decision issued on August 24, the U.S. Court of Appeals for the Second Circuit limited the reach of the Foreign Corrupt Practices Act (FCPA) by holding that theories of conspiracy or complicity cannot be used to charge non-U.S. citizens who do not work for a U.S. business and whose furtherance of corrupt schemes takes place outside the United States. Judge Rosemary S. Pooler wrote the majority decision in United States v. Hoskins, No. 16-1010, and Judge Gerard E. Lynch authored a concurring opinion.

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