One FCPA World

Suppose a group of officers of one of your foreign-based corporate clients, with no offices or businesses in the United States, makes a rare visit to the U.S. for an industry-related conference. Between sessions, they break off to participate in a conference call with employees overseas. The subject is whether to authorize political contributions in another country in the hope of getting business there, and they tell their compatriots to proceed. As soon as the conference is over, they head home. Can this one call be the basis for an assertion of U.S. jurisdiction over your client and the officers under the Foreign Corrupt Practices Act (FCPA)? Surprisingly, the answer is yes, in spite of the entirely accidental nature of the contact.

16 minute readDecember 27, 2004 at 09:39 AM
By
Jeffrey T. Green
One FCPA World

Suppose a group of officers of one of your foreign-based corporate clients, with no offices or businesses in the United States, makes a rare visit to the U.S. for an industry-related conference.

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