Over the past few years, the US government has taken an expansive view of who qualifies as a “Foreign Official” under the FCPA. A recent DOJ advisory opinion took the position that a member of a royal family did not qualify as a Foreign Official for FCPA purposes, leading to speculation that the government had relaxed its standards of who qualifies under the term. However, as the new FCPA Guidance demonstrates, companies should not assume that the DOJ or the SEC have narrowed their view.
Robertson Park has joined the firm as a partner in its Washington, D.C. office. Mr. Park's arrival is yet another milestone for this prestigious financial services law firm as it continues to attract top litigation and regulatory talent since first opening its doors in 2010.