wrongful acts were committed outside the United States by a foreign corporate defendant. The scope of ATS was more strictly limited to preclude foreign corporate defendants as parties in Jesner v. Arab Bank, PLC. ATS claims have been limited to foreign national plaintiffs and did not provide jurisdiction for lawsuits against foreign governments. Eleven years after Filartiga, Congress enacted the Torture Victims Protection Act, creating a cause of action which, until then, had existed in the common law, however this too has been restricted in scope to individuals who torture or commit extrajudicial killings, and not to corporations or political associations like the Palestine Liberation Organization (see Mohamad v. Palestinian Authority). Because individuals often don't have the means to pay large damage awards in these kinds of cases, the Seventh Circuit in Boim v. Quranic Literacy Institute gave voice to the idea that allowing claims to proceed against organizations and states that finance FTOs would "imperil the flow of money and discourage the financing of terrorist acts" by making it unprofitable. Other Congressional statutes enacted post-Filartiga have created other avenues to pursue claims against foreign governments like the Anti-Terrorism Act and amendments to the Foreign Sovereign Immunities Act that have broadened the scope of the types of property against which execution can be sought to satisfy judgments under FSIA's terrorism exception). Notes External links Text at: OpenJurist Case Brief: Filartiga v. Pena-Irala United States Court of Appeals for the Second Circuit cases 1980 in United States case law Alien Tort Statute case law Paraguay–United States relations Operation Condor Venue (law) 1976 in Paraguay Alfredo Stroessner