After a string of losses involving the largest Federal Corrupt Practices Act (FCPA) case against individuals, the U.S. government has now dismissed the Superseding Indictment and all underlying indictments.

The FCPA, 15 U.S.C. §§ 78dd-1, et seq., makes it illegal for U.S. companies and citizens, foreign companies listed on a U.S. stock exchange, or any person acting while in the United States to make payments to foreign government officials to assist in obtaining or retaining business. The FCPA specifically prohibits a person or company from making a bribe to a foreign official to influence that official to violate his or her lawful duties, or to secure an improper advantage in obtaining or retaining business.

In late 2009 and early 2010, a District of Columbia grand jury indicted 22 defendants, charging them with, among other things, violations of the FCPA and conspiracy to violate the FCPA. The indictments all related to a purported deal to sell $15 million in military and law enforcement products to the Ministry of Defense for Gabon. The case is often referred to as the “SHOT Show Case” because the vast majority of defendants were arrested at a shooting and hunting convention in Las Vegas in January 2010. Originally the grand jury issued 16 indictments against the 22 defendants, but the grand jury later issued a Superseding Indictment in April 2010 that consolidated all 22 defendants into one case, the largest ever for an FCPA case.

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