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OFAC Expands Reporting Requirements for Rejected Transactions

In late June, with minimum notice or fanfare, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule (the “Interim Rule”) that, inter alia, introduced new, broad requirements for covered parties to report rejected transactions.

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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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