On June 20, 2016, the United States Supreme Court delivered its opinion [3] in RJR Nabisco v. European Community, where it applied the presumption against extraterritoriality to the Racketeer Influenced and Corrupt Organizations Act (RICO), holding that RICO applies to acts conducted outside the United States only where the statutes that criminalize the underlying acts allow for it. The case tracks the Court’s extraterritoriality jurisprudence in Morrison v. National Australia Bank [4] and Kiobel v. Royal Dutch Petroleum [5]. The European Community and twenty-six of its member states, relying on RICO's private right of action, claimed that RJR Nabisco and related entities participated in a global money-laundering scheme in which drug traffickers smuggled narcotics into Europe and sold them for euros that were subsequently used to pay for large shipments of RJR cigarettes into Europe. These activities, the plaintiffs argued, were harmful in various ways, including lost tax revenue and increased law enforcement costs. The Court viewed the issue of RICO’s extraterritoriality as a twofold question: First, whether the Act’s substantive provisions apply to conduct that occurs in foreign states. Second, whether the Act’s private right of action applies to injuries suffered in foreign states. As to the first, the Court held that some of RICO’s substantive provisions apply extraterritorially but only to the extent that the predicates alleged in a given case themselves apply extraterritorially. The Court reasoned that Congress gave a clear, affirmative indication that RICO’s substantive provisions apply extraterritorially by incorporating predicates that apply to at least some foreign conduct. The Court was careful to warn, however, that “[a]lthough a number of RICO predicates have extraterritorial effect, many do not [and the] inclusion of some extraterritorial predicates does not mean that all RICO predicates extend to foreign conduct.” As to the second question, the Court held that RICO’s private right of action does not overcome the presumption against extraterritoriality. Its reasoning was based partly on the logic of Kiobel, which interpreted a strictly jurisdictional statute independently of the conduct governed by substantive law. Moreover, the Court averred that permitting recovery for foreign injuries in a civil RICO case presents a danger of “international friction” too great to bear without clearer direction from Congress. Thus, a private RICO plaintiff must allege and prove a domestic injury to business or property; the Act does not allow recovery for foreign injuries.