Conrad Black’s criminal convictions in the United States have been whittled down to just one count of fraud and another of obstruction of justice. A U.S. appeals court today reversed two counts of fraud against the former CEO of Hollinger International Inc. Black, who was accused along with other executives of defrauding shareholders of the newspaper company, has already served more than two years in a Florida prison in relation to the charges. The appeals court was tasked with determining whether Black’s original fraud charges should still stand after the U.S. Supreme Court earlier this year significantly narrowed the definition of so-called “honest services” fraud that prosecutors had used in their arguments against him. It’s now up to prosecutors to decide whether he should be retried on the reversed charges—an eventuality that several legal experts have suggested is unlikely. Although Black will now have to be re-sentenced on the remaining charges, it’s not clear whether he will need to go back to jail.