How Money Laundering Allegations Turn Foreign Violations Into Domestic Cases

Federal prosecutors are increasingly flexing their jurisdictional muscle by anchoring U.S. criminal and civil cases to violations of foreign law. Their strategy has been to leverage U.S. statutes that make “specified unlawful activity” (SUA) a basis for violations of U.S. law, even when the statute making the activity “unlawful” is a foreign statute. This enables prosecutors to pursue criminal charges, civil money laundering cases and asset forfeitures based on foreign offenses, converting foreign violations into powerful domestic enforcement tools. In a guest article, Pryor Cashman partner Jeffrey Alberts and associate Aaron Wiltse look at the statutory language regarding SUAs, including how courts have interpreted this language in recent cases. See “How the DOJ Keeps Stretching Its Extraterritorial Reach” (Jul. 31, 2024).

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