Anti-Bribery/Anti-Corruption

Patrick Linehan, Zoe Osborne, Brittany Prelogar, Katherine Dubyak, and Jefferson Klocke co-authored an article titled “Considerations For Conducting Remote Internal Investigations” for Law360. The article, published April 3, discusses some of the legal and practical considerations in conducting remote investigations as the world grapples with containing the spread of COVID-19.

On February 26, 2020, the US District Court for the District of Connecticut partially overturned the jury conviction of Lawrence Hoskins in United States v. Hoskins, acquitting the defendant of all Foreign Corrupt Practices Act (FCPA) counts. In doing so, the court found that the government had failed to demonstrate as a matter of law that Hoskins, a British citizen, had acted as an “agent” of Alstom Power Inc. (API), a US-based subsidiary of French multinational corporation Alstom S.A. (Alstom), and a “domestic concern” for purposes of FCPA jurisdiction. This ruling is the latest twist in a case that has dealt a series of blows to the DOJ’s expansive assertion of FCPA jurisdiction over foreign defendants. As described below, however, the DOJ still has a number of tools available to prosecute non-US defendants involved in foreign corruption.

Continue Reading The FCPA’s Arm Remains Long: Recent Developments in FCPA Jurisdiction over Non-US Defendants

Click here to read Steptoe & Johnson LLP’s 2019 FCPA/Anti-Corruption Year in Review.

US Foreign Corrupt Practices Act (FCPA) enforcement authorities announced a steady stream of individual and corporate enforcement matters throughout 2019, some with eye-popping fines. Overall, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) reported 50 FCPA-related actions (including 31