A “foreign official.”
Without one, there can be no FCPA anti-bribery violation (civil or criminal). Who were the alleged “foreign officials” of 2021?
This post highlights the alleged “foreign officials” from 2021 corporate DOJ and SEC FCPA enforcement actions. Compared to prior years, this year in review statistic (like many from 2021) is less than enlightening given the small number of corporate enforcement actions in 2021.
There were four core FCPA enforcement actions in 2021. Of the four actions, three (75%) involved, in whole or in part, employees of alleged state-owned or state-controlled entities (“SOEs).