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Five lessons from ex-Vitol traders FCPA conviction

Published on: 22 May 2024
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Table of contents

  • Indictment, superseding indictments and another indictment in another district
  • Takeaways
  • Aguilar's double indictments provide a cautionary tale for foreign bribery defendants
  • Be wary of alternative theories regarding a ‘domestic concern’
  • Money laundering carries the day in jury instructions
  • The government will continue to use the money laundering statute and Title 18 of the US Code, Section 1956(c)(7)(B)(iv)
  • Defence counsel should challenge various applications of the foreign bribery laws

Article summary

Law360: The government's 23 February 2024 victory in US v Aguilar in the US District Court for the Eastern District of New York is a cautionary tale that two indictments in two districts is a possible outcome for a foreign bribery defendant.

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