The Yale Law Journal

Daniel E. Herz-Roiphe

Comment

Innocent Abroad? Morrison, Vilar, and the Extraterritorial Application of the Exchange Act

Daniel E. Herz-Roiphe

During the fall of 1919, two American sailors bound for Rio de Janeiro hatched a plan to defraud the United States government.1 When their scheme—which involved an unscrupulous Standard Oil agent, a Rio-based shipbuilder, and a large quantity of fuel—came to the attention of American…