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Expert Analysis

Accessory Liability Still Can't Extend FCPA Jurisdiction

Law360, New York (April 19, 2016, 11:09 AM EDT) -- The government's practice of charging individuals with conspiracy to violate the Foreign Corrupt Practices Act, rather than with substantive FCPA violations, has, in many instances, yielded procedural and substantive benefits for the prosecutors. Conspiracy charges have been used to extend the five-year statute of limitations, as conspiracies are presumed to continue until their illegal objectives are fulfilled, as well as to establish FCPA jurisdiction beyond statutory provisions....

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