This post from last year pondered whether individuals associated with LIV Golf, financed by the Saudi Arabian Public Investment Fund (“PIF” – one of the largest sovereign wealth funds in the world) are “foreign officials” under the Foreign Corrupt Practices Act given how this element of the FCPA’s anti-bribery provisions has been interpreted by the DOJ and SEC.
The question is perhaps more pressing now given the announcement last week that the PGA Tour, LIV Golf (PIF) and the DP World Tour “have signed an agreement that combines PIF’s golf-related commercial businesses and rights (including LIV Golf) with the commercial businesses and rights of the PGA TOUR and DP World Tour into a new, collectively owned, for-profit entity.”