Tag Archives: Individual Prosecutions

Hoskins May Limit Extraterritorial Enforcement of U.S. Sanctions

The Second Circuit’s recent decision in United States v. Hoskins may impact enforcement of U.S. economic sanctions programs. The Hoskins decision precludes the government from charging a foreign national acting abroad with violating the Foreign Corrupt Practices Act (“FCPA”) through theories of conspiracy and accomplice liability. This holding is equally applicable to U.S. sanctions law.… Continue Reading

This is a Collect Call from The Department of Justice

Not too long ago I was clicking through the greatly improved DOJ FCPA webpage when I stumbled onto an enforcement action that had flown under the anticorruption/compliance blogosphere’s radar.  Yes, Manuel Salvoch had escaped the dreaded DOJ press release, but not the Fraud Section’s posting of documents for the world to see.  It was only … Continue Reading

Bonny Island Keeps on Giving (to the US Treasury that is)

On Friday, March 11, Jeffrey Tesler, who had challenged extradition from the UK to the US, relented in his fight and pleaded guilty to one count of conspiracy to violate the FCPA and one substantive violation of an FCPA antibribery provision.  In 2009, the DOJ initially charged Tesler in an 11 count indictment consisting of … Continue Reading

What to Look for in 2011

Recently, we wrote about the 2010 enforcement environment.  Today’s post looks forward to 2011 and some things to keep an eye out for in the coming year.  Without further ado: Prosecutions of Individuals. In 2010 we saw a significant number of individuals prosecuted for FCPA and related violations.  A number of defendants resolved their prosecutions … Continue Reading
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