Kirkland Alert Kirkland & Ellis LLP

Second Circuit Draws a Line in the Sand: DOJ Cannot Use the Conspiracy and Complicity Statutes to Expand the FCPA's Extraterritorial Reach

On August 24, 2018, in a closely followed case, the U.S. Court of Appeals for the Second Circuit issued an opinion that clarified the application of the Foreign Corrupt Practices Act (“FCPA”) to non-U.S. persons.