DOJ’s Long Arm Over Latin America: Recent Trends and Future Risks From Extraterritorial Application of U.S. Laws

The U.S. government has demonstrated a clear willingness to aggressively prosecute bribery far beyond its borders, and against foreign actors who very often believe themselves to be unreachable. In this guest article, Kobre & Kim attorneys Evelyn Sheehan and Jason Short explain how Latin America has proven itself a fertile testing ground for the DOJ’s ongoing expansion of FCPA-related investigations and forfeitures, and discuss other ways the DOJ is expanding its reach, from increasing domestic resources such as the Miami International Corruption Squad to more effectively pursue international kleptocracy matters, to using AML statutes to maximize forfeiture recoveries and reach foreign actors ordinarily beyond the purview of the FCPA. See “DOJ Enforcers Tout Transparency, the Defense Bar Responds” (Dec. 11, 2019).

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