Zachary Goldman, Erin Sloane, Emily Stark and Jason Raymond1
With a different structure from the US Foreign Corrupt Practices Act (FCPA), the Money Laundering Control Act (MLCA) has become an important tool in the US government's fight against international corruption. The reach of the MLCA is not limited to individuals or companies who personally visit the shores of the United States. Indeed, federal prosecutors have increasingly used the MLCA to charge foreign officials and others in international bribery schemes who had limited or no direct contact with the United States, especially...