How does the FCPA define foreign officials?

The FCPA's anti-bribery provisions only apply to things of value offered or given to "foreign officials." But the definition of "foreign official" is significantly broader than what many would expect. It includes any officer or employee of a foreign government or any department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on behalf of any such government or department, agency, or instrumentality, or for or on behalf of any such public international organization.

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