Is Anyone Not a Foreign Official Under the FCPA?

The DOJ has brought cases against companies and individuals in relation to their dealings with state-owned enterprises based on a broad reading of the term "instrumentality," a term not otherwise defined in the statute prohibiting corrupt payments to "foreign officials.

10 minute read January 26, 2011 at 12:30 AM
By
Jacqueline C. Wolff And Nirav Shah
Is Anyone Not a Foreign Official Under the FCPA?

Recent years have seen a rise in the number of enforcement actions taken by the Department of Justice (DOJ) and the Securities Exchange Commission (SEC) under the Foreign Corrupt Practices Act (FCPA), as well as a notable expansion of the types of conduct covered by these prosecutions.

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