A U.S. Department of Justice (DOJ) opinion about whether certain conduct is prohibited by the Foreign Corrupt Practices Act (FCPA) has sent shock waves through the FCPA world as it appears to reverse the long-standing view of who a "foreign official" is under the act. In the opinion, the DOJ announced that "a member of the royal family of [a] Foreign Country . . . does not qualify as a foreign official" under the FCPA "so long as the Royal Family Member does not directly or indirectly represent that he is acting on behalf of the royal family or in his capacity as a member of the royal family." For an analysis of the opinion, click here.