The Supreme Court denied the petition for certiorari filed by Joel Esquenazi and Carlos Rodriguez, former telecommunications executives convicted of FCPA violations for paying kickbacks to employees of the Haitian state telecommunications company, Telecommunications D’Haiti S.A. (“Haiti Telco”). Esquenazi v. United States, 135 S. Ct. 293 (2014) (No. 14-189) (mem.).  Esquenazi and Rodriguez had urged the Court to review the Eleventh Circuit’s holdings that Haiti Telco is an “instrumentality” of the Haitian government for purposes of the FCPA and that its employees are foreign officials.