SEC and Magyar Telekom defendants battle over a new use of FCPA’s ‘instrumentality of interstate commerce’ clause

The SEC has argued that Andras Balogh, Elek Straub, and Tamas Morvai were personally involved in the process of submitting periodic securities filings, and that their actions implicated the use of United States interstate commerce — one of the jurisdictional hooks of the Foreign Corrupt Practices Act.