6th Circuit Precludes Relief by Private Parties under Foreign Corrupt Practices Act

On September 28, 1990, in Lamb v. Phillip Morris Inc., a case of first impression at the federal appellate level, the United States Court of Appeals for the Sixth Circuit ruled that businesses injured by a competitior's unlawful influencing of foreign government officials do not have an implied right to sue under the Foreign Corrupt Practices Act (FCPA).