\On February 26, 2020, in United States v. Hoskins, the Hon. Janet Bond Arterton of the United States District Court for the District of Connecticut granted Defendant Lawrence Hoskins’ motion for a judgment of acquittal with respect to six counts of violating the Foreign Corrupt Practices Act (FCPA) and one count of conspiracy to violate the FCPA. Hoskins is a British citizen who was living outside the United States and was employed by a United Kingdom subsidiary of a power and transportation company, Alstom S.A. (Alstom). Alstom also has a United States-based subsidiary (Alstom U.S.), which hired consultants to pay bribes to Indonesian officials in order to secure a valuable contract for Alstom and its subsidiaries to build power stations for Indonesia’s state-owned electricity company. The government alleged that Hoskins was one of the individuals responsible for approving the selection of, and authorizing payments to, the consultants to direct corrupt payments to Indonesian officials. Hoskins was convicted after trial of six counts of violating the FCPA, one count of conspiracy to violate the FCPA, three counts of money laundering, and one count of conspiracy to commit money laundering. In granting Hoskins’ motion for a judgment of acquittal of the FCPA charges, the district court concluded that the evidence could not establish the existence of an agency relationship between Hoskins and Alstom U.S. The district court distinguished evidence that Alstom U.S. controlled the overall project of hiring consultants from evidence that Alstom U.S. controlled the actions of Hoskins himself, concluding that only the latter would establish FCPA liability in the circumstances. In so holding, the district court focused on the absence of facts that typically establish an agency relationship, such as the right to terminate the arrangement with Hoskins. Separately, the district court denied Hoskins’ motion for acquittal with respect to the four counts of money laundering charges.