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The impact of the U.S. Supreme Court’s decision this year limiting the extraterritorial application of U.S. securities laws in Morrison v. National Australian Bank has extended to another area of the law. The 2nd U.S. Circuit Court of Appeals has ruled that the reach of the Racketeer Influenced and Corrupt Organization Act was limited in a case alleging several foreign entities engaged in a widespread racketeering and money laundering scheme to try and seize control over most of the Russian oil industry.

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