The U.S. Supreme Court's logic & reasoning used in its June decision in Morrison v. National Australia Bank Ltd. -- where the Supreme Court rejected the application of U.S. securities laws abroad and reaffirmed the presumption that, when "a statute gives no clear indication of an extraterritorial application, it has none" -- was applied by New York Southern District Judge Jed S. Rakoff last Wednesday to an international civil racketeering case.
A Law.com article this morning says "Rakoff made the ruling in Cedeño v. Intech Group Inc., 09 Civ. 9716, where plaintiff Eligio Cedeño sought damages for a 'wide-ranging money laundering scheme' by Venezuelan officials and their allies 'that utilized New York-based U.S. banks to hold, move and conceal the fruits of fraud, extortion and private abuse of public authority.'"
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