A “foreign official.”
Without one, there can be no FCPA anti-bribery violation (civil or criminal). Who were the alleged “foreign officials” of 2020?
This post highlights the alleged “foreign officials” from 2020 corporate DOJ and SEC FCPA enforcement actions.
There were 12 core FCPA enforcement actions in 2020. Of the 12 actions, 100 (83%) involved, in whole or in part, employees of alleged state-owned or state-controlled entities (“SOEs).