I had to go through FCPA training for my employer a while ago, so take all this with a grain of salt: As I understand it, the FCPA covers U.S. companies and th

I had to go through FCPA training for my employer a while ago, so take all this with a grain of salt: As I understand it, the FCPA covers U.S. companies and their foreign affiliates and companies/organizations that trade securities in the U.S. If any employee or agent of such an organization bribes a foreign official, the DOJ or the SEC can go after them. "Foreign official" is defined really broadly as well. It includes foreign government employees, but also employees of international agencies and employees of government-managed industries (like doctors working for a state university hospital.) Also, the payment has to be illegal and not just "grease" money to speed up an ordinary task. Again, I'm not a lawyer, but the DOJ might be able to draw a line from various U.S. individuals to various FIFA board members or from US Soccer to FIFA itself depending on how broad the definitions are. If they get that second one, everybody on FIFA's board is screwed.