The US anti-bribery/anti-corruption and compliance world has literally been “a-twitter” over the filing of a brief which puts squarely before a federal district court the questions of just what is an “instrumentality” of a foreign government and who is a foreign government official under the Foreign Corrupt Practices Act (FCPA).

The individual defendants were all former employees of the California valve-maker Control Components Inc., (CCI), of Rancho Santa Margarita, California. While the case has been ongoing for over two years, we thought that it might be a propitious time to review the background facts of the case and the allegations against the individual defendants. Today we will discuss the background facts and the plea of the company. In tomorrow’s post, we will discuss the criminal allegations, separate and apart from the FCPA allegations against the individual defendants.