What Happens Abroad No Longer Stays Abroad

Law360, New York (October 1, 2012, 1:42 PM EDT) -- For multinational companies with operations in or other connections to the U.S., one of the most daunting aspects of a global compliance program is the extraterritorial application of U.S. export controls, sanctions regimes and anti-bribery laws. U.S. authorities may treat even those businesses that have seemingly little or no connection to the U.S. as subject to U.S. laws under novel theories of jurisdiction based on ever-expanding government interpretations of what qualifies as a “U.S. item” or a “U.S. person.”

The recent increase in high-stakes enforcement actions...
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