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Cracks in the Foundation: Sargeant Marine Inc. Pleads Guilty and Agrees to Pay $16mm for Bribery Schemes

On September 22, 2020, Sargeant Marine Inc. (“SMI”), an asphalt company incorporated and based in Boca Raton, Florida, pled guilty to conspiracy to violate the Foreign Corrupt Practices Act (“FCPA”) in Brazil, Venezuela, and Ecuador.

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Two Recent Decisions Provide Rare Guidance on the FCPA's Reach Over Foreign Nationals

Time to Read: 1 minutes Practices: Anti-Corruption / International Risk, Government Enforcement / White Collar Criminal Defense

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Two recent district court decisions have shed light on the reach and scope of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign nationals: SEC v. Straub and SEC v. Sharef. For companies and individuals operating abroad, these cases provide rare judicial guidance on the reach of the FCPA’s anti-bribery and record-keeping provisions. Together, they reaffirm U.S. regulators’ long-standing position that the FCPA has broad applicability to foreign nationals, while also setting the outer limits of the civil scope of the FCPA.

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