OFAC Asks Non-U.S. Persons to Advance U.S. Foreign Policy

June 7, 2021Business Crimes Bulletin

In recent years, U.S. prosecutors and regulators have shown increasing interest in prosecuting people and entities with little or no connection to the United States. This trend has been especially pronounced in the context of the Foreign Corrupt Practices Act (FCPA). See, Harry Sandick & Devon Hercher, “New FCPA Decision Limits DOJ’s International Reach,” Business Crimes Bulletin (May 2020) (stating that a majority of firms charged with FCPA violations are non-U.S. firms). This trend extends beyond the FCPA to the prosecution of white-collar crime more generally. See, Harry Sandick & Jeff Kinkle, “The Global Reach of U.S. Law Enforcement,” N.Y. Law Journal (Dec. 10, 2018).

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