Mulligan and Anker Publish Article on Appeals Court Decision on FCPA's "Instrumentality"

Bloomberg's World Securities Law Report
August 2014

In August of 2014, Bloomberg's World Securities Law Report published an article by Friedman Kaplan partners Mary E. Mulligan and Kent K. Anker discussing the recent decision by the U.S Court of Appeals for the Eleventh Circuit in United States v. Esquenazi, which clarified the reach of the term "foreign official" under the Foreign Corrupt Practices Act. Ms. Mulligan and Mr. Anker's article discusses the decision's implications for companies that do business abroad and offers suggested steps for in-house counsel and compliance officers to use in helping to ensure that their companies remain in compliance with FCPA regulations. FKSA associate Tanvir Vahora assisted in the preparation of the article.