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FCPA Blog Daily News

Entries in Jurisdiction (93)


Practice Note: New French law expands jurisdiction over foreign graft

In December 2016, France enacted an anti-corruption law known as Sapin II. The law was named after Michel Sapin, the then Minister of Finance, who said when presenting the bill: “In the fight against corruption, France cannot just satisfy itself with the existing situation.”

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Angela Barkhouse: Kleptocrats should face the International Criminal Court

The arguments for prosecuting grand corruption at the International Criminal Court as a crime against humanity are persuasive.

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Why some doctors at China state-owned hospitals may not be ‘foreign officials’

A recent scandal at a major Chinese public hospital revealed that many of the public hospitals across the country outsource their medical services to private companies and employ doctors as independent contractors.  That could raise doubts about some public hospital doctors in China being "foreign officials" under the FCPA.

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Kristy Grant-Hart on ISO 37001: Yes, we need one standard to rule them all

Have you ever sat across from your joint venture partner in Indonesia. Romania or Taiwan trying to explain why the United States Federal Sentencing Guidelines make it so their employees should be provided with anti-bribery training? I have, and it isn't a fun conversation.

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No FCPA jurisdiction based solely on conspiracy and accomplice liability, court rules

On March 16, the U.S. District Court for the District of Connecticut affirmed its earlier ruling that a non-resident foreign national cannot be charged with conspiracy to violate the Foreign Corrupt Practices Act or with aiding and abetting a violation of the FCPA, unless the government can show that he acted as an agent of a “domestic concern” or while physically present in the United States.

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Case note: Prosecuting foreign bribery without FCPA charges

Preet Bharara, U.S. attorney for the Southern District of New YorkLast week the DOJ charged four bankers from Honduras in a multi-year scheme to launder drug money and bribe foreign officials through accounts located in the United States.

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Double jeopardy? Siemens defendant loses Argentina dismissal motion

The Cámara Federal de Casación Penal of the Republic of Argentina issued an important ruling on May 4 concerning the legal principle that no one can be punished twice for the same crime (non-bis-in-idem).

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FIFA: 'When you have this closed circle, it's business as usual' (with video)

Here's a clip from VOA News featuring Jennifer Arlen, a New York University law professor, and Alexandra Wrage of Trace International.

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SEC declination for South Africa's Gold Fields

South African miner Gold Fields Ltd. issued a statement Monday saying the SEC closed its FCPA investigation and won't recommend an enforcement action against the company.

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Brazil's Electrobras hires Hogan Lovells for bribery investigation

Dear FCPA Blog,

You may have seen this announcement in an SEC filing on June 10 by the Brazilian-owned electric company Centrais Eletricas Brasileiras SA –Electrobras:

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SEC declination for South Africa's Net1

Net 1 UEPS Technologies said in a securities filing Monday that the SEC isn't recommending an enforcement action after investigating possible violations of the Foreign Corrupt Practices Act.

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On CNN, Dean Tillipman defends FIFA enforcement action

FCPA Blog senior editor Jessica Tillipman appeared Sunday on Fareed Zakaria's GPS on CNN. She and Harvard Law Prof Noah Feldman debated whether the DOJ overreached with the FIFA indictments last month.

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