The term of foreign official is defined broadly when used in reference to the FCPA, Foreign Corrupt Practices Act and the policies, procedures and laws that are outlined.  A person holding the title of the Minister of Finance, who also owns a bank or financial institute is considered to be a foreign official and held to comply with the FCPA.  Any doctor employeed and practicing in a government run or owned hospital is considered so as well as the employee of any other government run enterprise an/or institution.  It is therefore deemed illegal to offer any sort of payment or favor to anyone working in these offices.

Any monetary amount that is exchanged for anything other than the payment of services rendered will be investigated and prosecuted, as it is the intent or act of bribery and not the amount that is taken into consideration.  Bribery includes the offer or the demand of such payments in order to grease the wheels so to speak, to speed up or guarantee services, as offering or demanding such favors in order to secure new business, or in exchange for continued business.  As well, all of these companies are required to practice the highest of standards with regards to their accounting and book keeping practices.

These provisions and regulations surrounding the accounting compliance work hand in hand with the provisions of the FCPA and anti-bribery policies and procedures.  All of the transactions are required to be accurately recorded and must reflect exactly what they should be reflecting, simply put, everyone must tell the truth.   This requires each institution to actively initiate manners of internal auditing and controls.  This will also serve to provide evidence in an institution defense should they become wrongly accused of any illegal actions.  If they can prove that the books are accurate, they will not be charged.  This will serve to protect their reputation as well as their business.

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