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How Broad Is the FCPAs Reach Over the Acts of Foreign Nationals?

March 20, 2013

By PALMINA M. FAVA & MOR WETZLER

Within the last few months, U.S. courts, the Department of Justice and the Securities and Exchange Commission clarified the reach of the FCPA over foreign nationals, and courts determined that physical presence is required to begin the statute of limitations for bribery claims. This article distills important takeaways from those authorities and provides insight on those issues, harmonizing the holdings of SEC v. Straub and SEC v. Sharef and the FCPA Resource Guide.