A recent article in the Financial Times by Simon Kuper, titled “How to buy a foreign election” reminded me that the FCPA specifically makes illegal more than simply bribing a foreign government official or some employed by a state owned enterprise to secure an improper advantage. The FCPA also makes illegal bribes paid to “any foreign political party or official thereof”; “any candidate for foreign political office”; or any person, while knowing that all or a portion of the payment will be offered, given, or promised to an individual falling within one of these categories, all if to secure an improper advantage.
