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Our team has unsurpassed experience in counseling and defending U.S. and foreign companies and individuals in matters relating to the U.S. Foreign Corrupt Practices Act and similar anti-corruption laws. We are frequently contacted when a potential corruption issue arises, and are go-to counsel for investigations and enforcement proceedings before the U.S. Department of Justice (DOJ), the Securities & Exchange Commission (SEC) and the Multilateral Development Banks, including the World Bank. In addition, we advise clients considering transactions in high-risk markets or with business partners with high anti-corruption risks. We also counsel clients who are designing compliance programs and in conducting risk assessments.

Second Circuit Review: Holding the Line on the Foreign Corrupt Practices Act

February 24, 2021

Litigation of counsel Martin Flumenbaum and firm chairman Brad Karp’s latest Second Circuit Review column, “Holding the Line on the Foreign Corrupt Practices Act,” appeared in the February 24 issue of the New York Law Journal. The authors discuss a rare decision delineating FCPA jurisdiction, the Second Circuit’s recent ruling in United States v. Hoskins. Declining to narrow the scope of the Act’s jurisdiction, the court remained open to liability, so long as law enforcement can make a credible argument that defendants fit into any of the Act’s defined categories. Litigation associate Alexandra Willingham assisted in the preparation of this column.

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