Foreign Corrupt Practices Act

Foreign Officials

The FCPA defines “foreign official” broadly.  The official need not be high-ranking and the designation applies also to the relatives and friends of the official.  In addition to including officials, agents and employees of a foreign government, the following persons would also qualify as foreign officials:

  • Professors of state universities.
  • Advisors to ministries, government agencies or government officials.
  • Members of government committees or panels.
  • Healthcare professionals at government-owned or controlled hospitals.
  • Employees of a public international organization (such as the World Bank).
  • Members of a royal family.

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