Criminal,
Corporate,
Administrative/Regulatory
Oct. 9, 2018
2nd Circuit Focuses FCPA Enforcement on Agency
The 2nd Circuit's ruling in United States v. Hoskins may provide further encouragement for foreign individuals and entities to test the DOJ's theories of FCPA prosecution in court.
Laura Kabler Oswell
Partner
Sullivan & Cromwell LLP
Phone: (650) 461-5600
Email: kablerl@sullcrom.com
On August 24, 2018, in United States v. Hoskins, the 2nd U.S. Circuit Court of Appeals affirmed in part and reversed in part a district court decision dismissing portions of a count of conspiracy to violate the Foreign Corrupt Practices Act. The Department of Justice alleged that Lawrence Hoskins, an employee of the U.K. subsidiary of power and transportation company Alstom S.A. ("Alstom"), directed and authorized corrupt payments by a U.S. subsidiary of Alst...
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