Second Circuit Affirms Patrick Ho’s FCPA and Money-Laundering Conviction

In 2019, following a jury trial, Chi Ping Patrick Ho was sentenced to 36 months’ imprisonment and fined $400,000 in the SDNY. In an opinion affirming the lower court’s conviction of Ho, the Second Circuit significantly expanded the relatively small body of FCPA jurisprudence, addressing statutory language in the FCPA regarding domestic concerns, determining that elements of the statute need not be mutually exclusive and clarifying a requirement in the money‑laundering statute that money travel “to” or “from” the United States. See “Sentencing in Micronesian Bribery Case Highlights DOJ’s Commitment to Individual Prosecutions” (Jun. 26, 2019).

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