FCPA Jurisidiction Over Foreign Entities
The FCPA has broad international application. That does not mean that the United States has authority over every individual on the planet Earth. In order to establish jurisdiction over a foreign agent of a U.S. company or non-U.S. issuer, a foreign entity must commit an act in furtherance of an FCPA violation “while in the territory of the United States.” 15 U.S.C. § 78dd-3. The...