U.S. Now Unlikely to Prosecute Thai Film Festival Bribery

By Matthew Richardson

United States FCPA prosecutions for extraterritorial misconduct are most attention grabbing when large corporations engage in corrupt activities. Few would first think of a Thai film festival as the cutting edge of anti-corruption efforts. Nevertheless, Thai tourism boss Juthamas Siriwan may now escape extradition to the United States, despite alleged receipt of bribes from a Hollywood producer. Her recent indictment in Thailand will likely preclude extradition due to existing treaty obligations between the two countries. This is another reminder that the reach of the FCPA in terms of either specific countries or conduct can remain surprising, and inconsistent. One could even imagine well-connected officials seeking domestic indictment to avoid potential extradition. Maybe there’s a Hollywood movie in it somewhere?