The FCPA defines “foreign official” broadly. The official need not be high-ranking and the designation applies also to the relatives and friends of the official. In addition to including officials, agents and employees of a foreign government, the following persons would also qualify as foreign officials:
- Professors of state universities.
- Advisors to ministries, government agencies or government officials.
- Members of government committees or panels.
- Healthcare professionals at government-owned or controlled hospitals.
- Employees of a public international organization (such as the World Bank).
- Members of a royal family.