Commonly referred to as the “territorial jurisdiction” provision of the FCPA, 15 U.S.C. § 78dd-3 receives considerably less attention than the provisions governing issuers (§ 78dd-1) and domestic concerns (§ 78dd-2). However, in light of the government’s willingness to test the bounds of dd-3, and its use of dd-3 as a basis for recent resolutions in cases where the conduct at issue occurred largely outside the United States, the potential reach of dd-3 is worth renewed attention. In a guest article, Aisling O’Shea and Colin Missett, attorneys at Sullivan & Cromwell, track the government’s use of dd-3 over the years, consider whether recent use of the territorial jurisdiction provision suggests an enhanced or renewed focus on it and offer guidance as to how the potential scope of dd-3 may be taken into account when conducting internal investigations. See “Hoskins Provides an Opportunity for Judicial Determination of the FCPA’s Jurisdiction,” (Oct. 8, 2014); and “For Now, Hoskins Sets a Limit on the FCPA’s Jurisdictional Reach,” (Sept. 23, 2015).