"Due Process" Limits on Criminal Enforcement of the FCPA against Non-U.S. Nationals Based on Extraterritorial Conduct

14 May 2013
FCPA Professor Blog
Earlier this year, two judges of the U.S. District Court for the Southern District of New York ruled on motions to dismiss SEC civil FCPA actions, invoking the International Shoe “minimum contacts” and “reasonableness” tests to determine whether the courts had personal jurisdiction over the foreign individual defendants in those cases.