Second Circuit Analyzes Contours of Bribery in Bank Corruption Case

January 15, 2024  |  New York Law Journal

In recent years, federal corruption prosecutions have faced uncertainty when brought under the mail/wire fraud statutes and Hobbs Act.  The Second Circuit’s recent decision in United States v. Calk, 87 F.4^th 164 (2d Cir. 2023) is a notable contrast.  In that case, the Second Circuit affirmed a conviction for bank bribery under 18 U.S.C. § 215, a statute directed at corrupt conduct in financial institutions.  In their latest article for the NYLJ, “Second Circuit Analyzes Contours of Bribery in Bank Corruption Case,” Morvillo Abramowitz partners Elkan Abramowitz and Jonathan Sack discuss the Second Circuit’s broad interpretation of the terms “corruptly” and “thing of value” as used in § 215, in reliance on similar language in other federal anti-corruption statutes. 

Second Circuit Analyzes Contours of Bribery in Bank Corruption Case (pdf | 156.73 KB)