Supreme Court Declines to Review Definition of a “Foreign Official” Under the Foreign Corrupt Practices Act: 11th Circuit’s

Oct 10, 2014

Reading Time : 1 min

By: Charles F. Connolly, Pratik A. Shah

In affirming the defendants’ convictions for violations of the FCPA, the 11th Circuit adopted a more expansive definition consistent with the prosecution’s position, holding that the FCPA’s bribery prohibition extends to payments offered or made to officers or employees of entities “controlled by the government of a foreign country that performs a function the controlling government treats as its own.” 

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