'Foreign Official' Under FCPA: Regal May Be Legal

Law360, New York (October 23, 2012, 12:32 PM EDT) -- The U.S. Department of Justice recently provided valuable guidance regarding whether members of royal families qualify as “foreign officials” under the U.S. Foreign Corrupt Practices Act. In its first FCPA advisory opinion issued in 2012, the DOJ concluded that the royal family member described in the request for opinion “does not presently qualify as a foreign official.” See Opinion Procedure Release 12-01 (Sept. 18, 2012).[1]

The DOJ’s decision here is somewhat surprising in light of the DOJ’s consistent attempts in recent years to broaden the scope...
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