W. EUGENE DAVIS, Circuit Judge:
We are presented for the first time with the question of whether the Foreign Corrupt Practices Act (FCPA) permits the prosecution of an employee for a substantive offense under the Act if his employer has not and cannot be convicted of similarly violating the FCPA. We conclude that the Act prohibits such a prosecution and affirm the district court.
I.
During the late 1970's Petroleos Mexicanos (Pemex), the national...
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