On November 8, 2019, after a much anticipated, two-week trial, a former senior executive at Alstom S.A. (Alstom), a French power and transportation company, was found guilty for his role in a multiyear, multimillion-dollar foreign bribery scheme and a related money laundering scheme. The conviction of Lawrence Hoskins reinforces the broad reach of the Foreign Corrupt Practices Act (FCPA), as Hoskins, a British citizen who worked in France and never set foot in the United States during his tenure at Alstom, was charged in 2013 related to conduct that occurred from 2002 to 2004. Hoskins’ conviction is also particularly significant given a U.S. Court of Appeals for the Second Circuit ruling last year that rejected part of the expansive view of the FCPA’s jurisdiction that the U.S. Department of Justice (DOJ) had initially asserted in Hoskins’ case. While the Second Circuit ruling remains a significant judicial check on the DOJ’s interpretations of the FCPA, Hoskins’ conviction indicates that the ruling has significant practical limitations.
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