The Second Circuit held that the FCPA’s anti-bribery provisions do not extend to non-U.S. persons absent a U.S. nexus. The holding specified that a nonresident foreign national cannot be held liable under the provisions under a conspiracy or accomplice theory if they could not otherwise be held liable under the statute. The Defendant in the case was a U.K. national employed by a U.S. corporation who had never been to the United States. The holding leaves open a potential avenue for the DOJ to prosecute foreign nationals under the FCPA by charging them as agents of U.S. companies. However, an aggressive interpretation of agency to reach foreign nationals with a minimal U.S. nexus could also face a successful legal challenge.