Quarterly FCPA Report: Third Quarter 2011
By The Global Compliance and Disputes Practice
The third quarter demonstrated that the Foreign Corrupt Practices Act (FCPA) continues to hold the attention of a broad audience, including in the courtroom. For the second consecutive quarter, a guilty jury verdict was handed down, this time for two executives in the Haiti Teleco case. Also for the second quarter in a row, the definition of foreign official was the subject of courtroom activity in the Control Components, Inc. (CCI)-related case, U.S. v. Carson et al. There, the U.S. Department of Justice (DOJ), in preparing its jury instructions, helped clarify an issue related to the definition of foreign official.