On 9 February 2015, in United States v Duperval, the Eleventh Circuit upheld the nine year prison sentence given to Jean Rene Duperval, a former Assistant Director General and Director of International Affairs of the company Telecommunications D’Haiti S.A.M., a state owned company based in Haiti. The initial conviction was given in relation to two separate schemes to launder bribes paid to him by two Miami-based telecommunications companies. This is the first conviction under the FCPA against a foreign official for money laundering offences.