A “foreign official.”
Without one, there can be no FCPA anti-bribery violation (civil or criminal). Who were the alleged “foreign officials” of 2019?
This post highlights the alleged “foreign officials” from 2019 corporate DOJ and SEC FCPA enforcement actions.
There were 14 core FCPA enforcement actions in 2019. Of the 14 actions, 8 (57%) involved, in whole or in part, employees of alleged state-owned or state-controlled entities (“SOEs).