November 05, 2013

In this article, Jenner & Block Partner Anthony S. Barkow and Associate Eddie A. Jauregui examine whether foreign defendants whose conduct occurred outside the United States are subject to U.S. jurisdiction under the Foreign Corrupt Practices Act (FCPA).  The authors view the issue through the lens of three recent rulings that, they observe, “should serve as reminders to foreign companies and individuals that the FCPA’s reach is broad and that even if their conduct occurs outside the United States, and is not principally aimed here, they could be held accountable for FCPA violations in U.S. courts.”