By Matthew
Richardson
United States FCPA prosecutions for extraterritorial
misconduct are most attention grabbing when large corporations engage in corrupt
activities. Few would first think of a Thai film festival as the cutting edge of
anti-corruption efforts. Nevertheless, Thai tourism boss Juthamas Siriwan
may now escape extradition to the United States, despite alleged receipt of
bribes from a Hollywood producer. Her recent indictment in Thailand will likely
preclude extradition due to existing treaty obligations between the two
countries. This is another reminder that the reach of the FCPA in terms of either
specific countries or conduct can remain surprising, and inconsistent. One
could even imagine well-connected officials seeking domestic indictment to
avoid potential extradition. Maybe there’s a Hollywood movie in it somewhere?
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