Last month, the 11th Circuit Court of Appeals issued a ground-breaking decision on a Foreign Corrupt Practices Act case that will have lasting effects and provides some clarity on the definition of an important aspect of the law—what constitutes a “foreign official.”
In an opinion released on May 16, the court upheld the convictions of Joel Esquenazi and Carlos Rodriguez for violations of the Foreign Corrupt Practices Act (FCPA) and certain U.S. anti-money laundering (AML) laws.

