Government,
Corporate,
Administrative/Regulatory
May 24, 2014
A first-of-its-kind FCPA ruling
The 11th Circuit held that an "instrumentality" is as "an entity controlled by the government of a foreign country that performs a function the controlling government treats as its own."
Debra Wong Yang
Partner
Gibson, Dunn & Crutcher LLP
333 S Grand Ave
Los Angeles , CA 90071
Phone: (213) 229-7000
Email: dwongyang@gibsondunn.com
Boston Coll Law School; Newton MA
Debra is a partner in the firm's Los Angeles office. Reflective of her broad practice and comprehensive abilities, Ms. Yang is Chair of the Crisis Management Practice Group, former Chair of the White Collar Defense and Investigations Practice Group, which includes the FCPA Practice Group and former Chair of the Information Technology and Data Privacy Practice Group. She is also a member of the firm's Executive Committee.
Court interpretations and analyses of the Foreign Corrupt Practices Act are few and far between notwithstanding the increasing penalties, some well over the $100 million mark, imposed on companies and individuals. As corporations continue to expand globally, the risk of violating the FCPA is ever present. And so, any interpretation of the FCPA has great meaning and import.
On May 16, the 11th U.S. Circuit Court of Appeals issued its much-anticipated decision in the appeal of Joel...For only $95 a month (the price of 2 article purchases)
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