The Foreign Corrupt Practices Act (FCPA) defines foreign official as any officer or employee of a foreign government or any department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on behalf of any such government or department, agency, or instrumentality, or for or on behalf of any such public international organization. The FCPA thus covers corrupt payments to low-ranking employees and high-level officials alike. The term “instrumentality” is broad and can include state-owned or state-controlled entities.
Foreign Official
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