Foley Partner David Simon authored an article that appeared on TheBriberyAct.com blog on May 12, 2011 titled “Is the Bribery Act ban on Commercial Bribery Such a Big Deal?” Simon discusses challenges to the United States Department of Justice’s interpretation of the Foreign Corrupt Practices Act’s (FCPA) “foreign official” element. He states that U.S. regulators have taken an expansive view of the meaning of “foreign official,” adding that difficult questions remain regarding the definition of “foreign official” and whether the government needs to be in a position of active control.
Click here to read the complete article.
Author(s)
Related Insights
14 February 2025
Foley Viewpoints
Wastin’ Away in Non-Complianceville
Everyone knows — or should know — that “The Terminator” is the best Halloween movie release and that “Die Hard” is the best Christmas movie (even though it was released in July).
06 March 2025
Events
SEC Enforcement Landscape: Lessons and Trends for Advisers
The SEC Enforcement program continues to aggressively pursue advisers on all fronts. This panel will discuss lessons from recent enforcement actions and insight into agency priorities that adviser legal and compliance personnel can incorporate into their firms’ compliance programs. Foley Partner Jim Lundy will moderate.
13 February 2025
Energy Current
Texas’ Power Transmission Infrastructure: Addressing Growing Demand from Data Centers and Crypto Mining
Texas is facing a rapidly evolving energy landscape, driven in part by the surging power demands of data centers and cryptocurrency mining operations.