Agency: A New Frontier for FCPA Jurisdiction

The Hoskins case highlighted the manner by which the DOJ (and the SEC, which has civil enforcement jurisdiction under the FCPA) can harness the common-law doctrine of agency to expand the reach of the statute.

10 minute read March 01, 2020 at 12:07 AM
By
Darren LaVerne, Michael Martinez and Eric Rosoff
Agency: A New Frontier for FCPA Jurisdiction

The U.S. Department of Justice's November 2019 trial conviction of Lawrence Hoskins, a UK citizen employed by the French energy company Alstom, for violating the Foreign Corrupt Practices Act (FCPA) drew increased attention to the global reach of U.S. law and DOJ policy in pursuing targets who have had little or no contact with the United States.

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