Never Been To The U.S.? You May Still Be Charged Under The FCPA

Foreign entities and individuals be on notice: The U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) are actively bringing Foreign Corrupt Practices Act (“FCPA”) cases based on activities that occur wholly outside the United States. In its latest foray into this area, the DOJ charged a South Korean national with an FCPA violation, not for any connection with the U.S. but for conspiring to violate the FCPA and aiding and abetting a U.S. company to pay a bribe to a foreign official. On 18 June 2014, the Ninth Circuit rejected his attempt to challenge the court’s jurisdiction from his home country of South Korea.

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