August 25, 2015

In this article, Jenner & Block Special Counsel Miwa Shoda and Associate Andrew G. Sullivan examine the recent string of US government enforcement actions taken against foreign officials who take bribes.  The authors analyze whether the US Department of Justice’s targeting of bribe-taking officials under the Money Laundering Control Act (MLCA) is an evasion of limitations that lawmakers have placed on the Foreign Corrupt Practices Act (FCPA).  They explore the jurisdictional scope of the FCPA and discuss legal issues related to the DOJ’s bellwether prosecution of a Thai official on MLCA charges.