At all levels, the term “foreign official” is very broadly defined to include:

• International organizations, political candidates and parties, government owned or controlled commercial enterprises, and government employees
• Private persons acting in an official capacity, including ceremonial advisors and consultants
• GOs who work in the health care field, such as physicians, nurses, pharmacists, and purchasing officers employed by government-controlled hospitals or universities

This broad definition is applied by US law enforcement officials even if local laws do not consider these same individuals to be GOs.