Are Royals Foreign Officials Under the FCPA?

Is the Prince of Wales a government official? Are his brothers? Are Saudi princes? Does it matter if the “royal” is in the line of succession and, if so, does it matter how far down the line? In this guest article, Shearman & Sterling partner Philip Urofsky and associate Oyinkan Muraina examine where royals fall into the FCPA’s definition of “foreign official” and how companies can navigate this issue and mitigate corruption risk despite the limited guidance and precedent. See also the ACR’s two-part series on managing corruption risk when hiring and training foreign officials and their relatives overseas: “Risks and Challenges” (Jul. 27, 2016) and “Practical Compliance Guidance” (Aug. 10, 2016).

To read the full article

Continue reading your article with an ACR subscription.