One U.S. District Court in New York Affirms Broad Jurisdictional and Temporal Reach of the FCPA While Another Dismisses FCPA Case for Lack of Contacts

Two federal judges sitting in the Southern District of New York recently reached different conclusions regarding how far the FCPA reaches.  Together, the two decisions provide legal analysis relevant to corporate decision-making on: the role of e-mail and computer servers in conferring jurisdiction over FCPA defendants; the interaction between preparation of SEC filings and jurisdictional questions; the level of authority over a bribe or cover up required to trigger jurisdiction; statute of limitations questions; and other topics.  This article analyzes both decisions.

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