A “foreign official.”
Without one, there can be no FCPA anti-bribery violation (civil or criminal). Who were the alleged “foreign officials” of 2016?
This post highlights the alleged “foreign officials” from 2016 corporate DOJ and SEC FCPA enforcement actions.
There were 27 core corporate enforcement actions in 2016. Of the 27 enforcement actions 21 (78%) involved, in whole or in part, employees of alleged state-owned or state-controlled entities (“SOEs) with 7 of the 21 (26%) actions involving, in whole or in part, individuals associated with foreign health care systems.