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At the crux of almost every Foreign Corrupt Practices Act (FCPA) internal investigation or government enforcement action involving alleged bribery is the question of whether the individual being allegedly bribed is a “foreign official” pursuant to the FCPA. This is so because the FCPA does not define who can be considered a foreign official. As a result, the government has consistently advocated for a broad interpretations of the term foreign official, attempting to expand the reach of the FCPA to include state-owned enterprises that are not a part of any foreign government and whose employees would then be considered foreign officials.

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