Corporate Compliance Insights
US District Court Rebuffed DOJ’s Basis for Claiming FCPA Jurisdiction Over Foreign Nationals. But New Precedent Is Unlikely
January 27, 2022
A U.S. District Court appeared to undermine an important aspect of FCPA cases – the determination of whether a foreign national can be considered a U.S. agent – in a November decision to dismiss charges against a Swiss wealth manager. Explanation for this move is scant, and questions abound.
Contacts

Capabilities
Suggested News & Insights
Fifth Circuit Panel Produces Three Opinions Wrestling with Application of First to File BarMarch 13, 2026Sidley Partner Lisa Miller to Speak at the 2026 WWCDA Annual Attorney Meeting in San DiegoWednesday, March 11, 2026Sidley Lawyers Karen Popp, Kristin Graham Koehler, and Lisa Miller to Speak at the ABA's 2026 White Collar Crime Institute in San DiegoTuesday, March 10 – Friday, March 13, 2026New U.S. DOJ Antitrust Leadership Signals More Criminal Prosecutions and Longer Prison SentencesMarch 6, 2026Notable Cases and Events in eDiscoveryMarch 6, 2026Strictly Enforcing Rule 9(b), Second Circuit Affirms Dismissal of FCA Claim Based on Allegedly Defective Medical DevicesMarch 4, 2026
- Stay Up To DateSubscribe to Sidley Publications
- Follow Sidley on Social MediaSocial Media Directory
