Defining and Dealing with “State-Owned” Entities in the FCPA Context
Stephanie M. Tennant
Associate General Counsel, Compliance
Meta
An Tran
Partner
Jenner & Block LLP
- What is (and isn’t) a “state-owned” entity, as defined in the FCPA-and the enduring grey areas
- Applying both ownership interests and level of control tests when determining whether something is “state-owned”
- Managing the inherent, heightened risks when dealing with state-owned entities
- Defining “instrumentality” in relation to essential government control, and understanding how/when instrumentalities are more/less important