A Jurisdictional Stretch?

An interesting DOJ criminal action alleging foreign bribery to highlight.
As highlighted in this recent press release an indictment was unsealed charging a Turkish national (Bahadir Hatipoglu) and a German national (Ralf Grywnow) for an alleged bribery scheme involving contracts with the U.S. military and the North Atlantic Treaty Organization (NATO).
As alleged in the indictment, Hatipoglu was the owner and General Manager of a Turkish construction company and Grywnow worked for the NATO Support and Procurement Agency (NSPA – an organization within NATO that served as a logistics and procurement agency supporting NATO’s mission).
According to the indictment, Hatipoglu and Grywnow engaged in a fraud scheme in which Hatipoglu bribed Grywnow “with money and other forms remuneration” and “in exchange [Grywnow] gave the construction company favorable treatment on NATO construction contracts and signed fraudulent evaluations of the company’s prior performance that favorably recommended the company for future projects with the United States military.” The indictment alleges that Hatipoglu “then used these evaluations to defraud and attempt to defraud the U.S. military.