How Hoskins Limits Extraterritorial Sanctions Enforcement
By Kevin McCart and Jacquelyn Desch ( September 26, 2018, 2:01 PM EDT) -- The Second Circuit's recent decision in United States v. Hoskins[1] precludes the government from charging a foreign national acting abroad with violating the Foreign Corrupt Practices Act through theories of conspiracy and accomplice liability, if the government could not charge the foreign national as a principal. This holding is equally applicable to U.S. sanctions law....
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