In the recently announced Foreign Corrupt Practices Act enforcement action against Daren Condrey (see here for the prior post), the DOJ advanced an extremely broad “foreign official” interpretation.
In short, the DOJ alleged that a Maryland resident (Vadim Mikerin), working for a Maryland corporation (TENAM Corporation), was a Russian “foreign official.”
How?
via Analyzing The DOJ’s Recent “Foreign Official” Enforcement Theory « FCPA Professor
