In today's uncertain economic times, as foreign governments implement varying bailout strategies for previously private enterprises, the number of "foreign officials" for Foreign Corrupt Practices Act purposes has the potential to dramatically increase, say attorneys Stephanie J. Meltzer and Christopher E. Tierney. This is particularly true given that the percentage of foreign government ownership or amount of control needed to deem employees "foreign officials" for FCPA purposes remains an open question.
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Has Economic Uncertainty Expanded Reach of the Foreign Corrupt Practices Act?
New York Law Journal
August 10, 2009
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