Menu9/25/18: In late August the Second Court’s decision in United States v. Hoskins established limits on the ability of DOJ to prosecute foreign nationals without direct ties to the US or a US company for FCPA violations. The decision sets new limits on DOJ’s expansive view of its powers under the FCPA and the risks faced by multi-national companies under the statute. A Client Memorandum released by law firm Davis Polk & Wardwell LLP explains the full decision and its ramifications on organizations going forward.
