Insights
Client Alert
Line in the Sand: What Actions Bring Foreign Nationals Within Reach of an FCPA Action
March 08, 2013
BY THE GLOBAL COMPLIANCE AND DISPUTES PRACTICE GROUP
Last month, two judges in the Southern District of New York issued decisions considering when enforcement actions by the U.S. Securities and Exchange Commission can proceed against foreign nationals in cases involving allegations of bribes paid in foreign countries. Viewed together, the decisions provide guidance in applying an otherwise case-specific analysis.