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The Foreign Corrupt Practices Act (FCPA) makes it a crime for “any officer, director, employee, or agent” of an issuer of U.S. securities “to make use of the mails or any means or instrumentality of interstate commerce” in furtherance of any corrupt offer, promise or payment to a foreign official. While much has been written about the FCPA’s various substantive violations, defenses and exceptions, very little has been written about the jurisdictional requirement of use of the “mails,” “means” or an “instrumentality” of interstate commerce. Until now.