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Until this year, there has been no judicial guidance on how Constitutional limits on U.S. federal courts’ exercise of personal jurisdiction apply in an FCPA case. Two recent decisions from the United States District Court for the Southern District of New York – SEC v. Straub, et al. and SEC v. Sharef, et al. – address that question in the context of civil FCPA charges brought by the Securities and Exchange Commission (SEC) against foreign nationals in two different alleged foreign bribery matters. The authors, Partners Iris E. Bennett, Jessie K. Liu , and Michael K. Lowman and Associate, Michael T. Borgia note that these decisions have potentially serious consequences for any corporation with a foreign subsidiary, as they would permit the SEC to bring FCPA charges against a foreign national employee operating entirely outside of the United States.