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Second Circuit Declines to Expand FCPA’s Jurisdictional Reach Using Conspiracy or Accomplice Liability Theories

September 28, 2018, Covington Advisory

On August 24, 2018, the Second Circuit issued its much-anticipated decision in U.S. v. Hoskins.Emphasizing on multiple occasions that Congress defined “with surgical precision” who could be liable under the anti-bribery provisions of the Foreign Corrupt Practices Act (“FCPA”), the court held that the government may not employ conspiracy or accomplice liability theories to bring charges against foreign defendants that do not fall within the statute’s explicit categories of covered persons.

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