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Congress enacted the Foreign Sovereign Immunities Act' in an effort to set forth the "sole and exclusive standards" for foreign sovereign immunity2 in United States courts.' The FSIA nevertheless fails to resolve the issue of when parties in United States courts may sue foreign states for the acts of nominally separate government instrumentalities.' These instrumentalities-government trading corporations, banks, and other commercial enterprises-may be judgment proof, yet they and the foreign state that owns or finances them may escape liability for commercial activity5 that harms American parties.' This Note addresses the problems that

Jurisdiction over Foreign States for Acts of Their Instrumentalities: A Model for Attributing Liability