Significant case law affecting the FCPA does not come around too often, but a recent ruling by a Texas judge may challenge the limits of territorial jurisdiction under the FCPA and the application of the Money Laundering Control Act of 1986 as sanctions for crimes with a limited nexus to the U.S. Tied to a larger set of charges related to state-owned oil company Petróleos de Venezuela SA (PDVSA), a November 2021 Texas court’s ruling to dismiss charges against Daisy Teresa Rafoi-Bleuler, a Swiss money manager, is sending shockwaves across the legal community. See “After Hoskins: Critical Takeaways from the Most Important FCPA Trial in Years” (Apr. 15, 2020).
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