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20 to the next problem: As Halberstam makes clear, people who aid and abet a tort can be held liable for other torts that were “a foreseeable risk” of the intended tort. 705 F. 2d, at 488. Accordingly, a close nexus between the assistance and the tort might help establish that the defendant aided and abetted the tort, but even more remote support can still constitute aiding and abetting in the right case.

Moreover, in appropriate circumstances, a secondary defendant’s role in an illicit enterprise can be so systemic that the secondary defendant is aiding and abetting every wrongful act committed by that enterprise—as in Halberstam itself. Id., at 487–488. At this point, aiding-and-abetting liability begins to blur with conspiracy liability, which typically holds co-conspirators liable for all reasonably foreseeable acts taken to further the conspiracy. See Pinkerton v. United States, 328 U. S. 640, 647–648 (1946); see also Halberstam, 705 F. 2d, at 482–483 (noting the occasional overlap). Yet, as noted above, aiding and abetting lacks the requisite agreement that justifies such extensive conspiracy liability. See Restatement (Second) of Torts §876, Comment a, at 316 (“The theory of the early common law was that there was mutual agency of each [conspirator] to act for the others”); Pinkerton, 328 U. S., at 646. Thus, while the facts of Halberstam are not totemic (lest courts strain to compare Linda Hamilton with international criminal syndicates), its facts are useful when determining whether a defendant has so consciously “participate[d] in” a series of tortious acts in order to “make [each one] succeed.” Nye & Nissen, 336 U. S., at 619 (internal quotation marks omitted).

To summarize the requirements of §2333(d)(2), the phrase “aids and abets, by knowingly providing substantial assistance,” points to the elements and factors articulated by Halberstam. But, those elements and factors should not