In affirming the conviction in the lower District Court of the Southern District of Florida of two men, Joel Esquenazi and Carlos Rodriguez, for bribing officials at a state-owned Haitian company, Telecommunications D’Haiti, SAM, the court held that officers, directors, or employees of any “entity controlled by the  government of  a foreign  country that  performs a function the controlling government treats as its own” could be considered a “foreign official” under the FCPA.