In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary resources. Belying its reputation as a month for summer vacations, August was yet another busy month, with a potentially significant adverse ruling in a DOJ FCPA enforcement action, several negotiated FCPA resolutions, a busy civil docket, and important anti-corruption developments in India, Thailand, the UK, and China. Here is our August 2015 Top Ten list:

1. DOJ Suffers Significant Setback in Alstom Individual Prosecution. An August 13, 2015 ruling by Connecticut U.S. District Judge Janet Arterton in United States v. Lawrence Hoskins dealt a potentially major blow to one of the central pillars of DOJ’s FCPA enforcement program. In A Resource Guide to the U.S. Foreign Corrupt Practices Act, DOJ stated that foreign nationals and companies “may . . . be liable for conspiring to violate the FCPA . . . even if they are not, or could not be, independently charged with a substantive FCPA violation.” Consistent with this position, Hoskins, a UK citizen assigned to an Alstom subsidiary in France, was charged with conspiring with Alstom’s subsidiary in Connecticut and others to violate the FCPA by paying bribes to Indonesian officials in exchange for a lucrative power station project contract. Judge Arterton ruled, however, that a nonresident foreign national who is not an agent of a domestic concern and commits no acts while physically present in the territory of the United States is excluded from FCPA substantive liability and, therefore, also cannot be charged with conspiring to violate the FCPA or with aiding and abetting an FCPA violation. This holding is essentially an extension of United States v. Castle,4 in which the Fifth Circuit held that, because Congress had intentionally omitted foreign officials from substantive FCPA liability, they could not be charged with conspiring to violate the FCPA.