The first U.S. trial conviction for foreign bribery cemented the fact that the Justice Department’s determination of who counts as a foreign official will be the law of the land unless a higher court invalidates it, experts said….
“The biggest message from the case is that companies around the world need to presume that employees of state-owned enterprises will be considered foreign officials under the Foreign Corrupt Practices Act,” said Rita Glavin, a partner at Vinson & Elkins LLP who formerly headed the Justice Department’s Criminal Division.
‘Enforcement 40’ for 2020
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