Kramer Quoted on Public Official Definition Under FCPA

Associate Alexander Kramer said increased publicity around the definition of a public official under the Foreign Corrupt Practices Act may encourage the Department of Justice (DOJ) to clarify the issue when further guidance on the law is issued. Kramer also said the DOJ may avoid providing too much guidance on the issue in order to allow flexibility in compliance prosecution, but added that companies may desire a more narrow definition so they can improve their own compliance programs.