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Limiting the Extraterritorial Reach of U.S. Criminal Law
The Eleventh Circuit recently vacated two defendants' money-laundering sentences because it found that they had “committed no crime against the United States.” United States v. Lopez-Vanegas, 493 F.3d 1305, 1306 (11th Cir. 2007). This decision was shocking because the defendants and their co-conspirators met in Miami numerous times to plan their conspiracy. At first blush, the court's decision seems to pose a significant obstacle to the increasingly broad extraterritorial application of U.S. criminal laws by the Department of Justice (DOJ). But when applied to conspiracies based on U.S. money laundering laws, does Lopez-Vanegas go far enough to prevent the DOJ from charging foreign nationals for conduct outside the U.S.?
The Lopez-Vanegas Case
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