World Cup Arrives in the United States: Navigating Anti-Corruption, Ethics and Political Influence Risks

Specifically, World Cup-related hospitality creates a concentrated risk environment that could implicate various federal statutes, including the Foreign Corrupt Practices Act (FCPA), the Foreign Extortion Prevention Act (FEPA), the Foreign Agents Registration Act (FARA) and the Travel Act. While these statues establish the legal boundaries, the ground-level risks are uniquely dangerous: premium corporate hospitality can serve as a direct vehicle for bribery or be manipulated to secure illegal entry into the United States to facilitate transnational crime. A complex mix of state gift rules further complicates this threat matrix, differentiating this tournament from any standard corporate entertainment venue.

Why Is the World Cup Different?
The legal risks associated with World Cup hospitality are not entirely unique. Companies routinely host customers, government officials and business partners at premium events such as the Super Bowl, World Series, Formula One races, the Olympics and major championship golf and tennis tournaments. What distinguishes the World Cup is the tournament’s global appeal, which may attract many more government officials, employees of state-owned enterprises, sovereign wealth fund personnel, regulators and procurement officials from around the world to the United States, where they are more readily subject to U.S. jurisdiction and enforcement.

Premium hospitality packages may cost thousands—or, for marquee matches and hospitality experiences, tens of thousands—of dollars per guest, often including exclusive seating, food and beverage service, private events, transportation and other benefits. As discussed in further detail, below, such hospitality creates a concentrated risk environment that could implicate various state and federal statutes, including the FCPA, FEPA, FARA and the Travel Act.

Playing Defense: Vetting, Monitoring and Response Strategies
Companies involved in either providing or receiving World Cup-related hospitality should follow compliance policies and carefully scrutinize proposed invitations, sponsorships, travel arrangements, entertainment packages and related benefits before they are approved. The analysis should focus not only on the value of the hospitality, but also on who is providing it, who is receiving it, the legitimate business purpose, whether any government official or state-owned-enterprise employee is involved, whether any business or regulatory matter is pending and whether the arrangement complies with applicable laws, internal policies, contractual obligations and ethics considerations. In conducting these reviews, organizations should implement specific contractual safeguards, including robust anti-corruption representations, strict gift-and-hospitality restrictions, mandatory audit rights and clear record-retention obligations.

Organizations should be prepared to act quickly where potential issues arise. Allegations that hospitality was offered, solicited or accepted in exchange for undue business advantage or other favorable treatment can trigger whistleblower complaints, internal investigations, regulatory inquiries or enforcement scrutiny—which can happen long after the tournament concludes, given statutes of limitations of five years or more. Prompt assessment, preservation of relevant records and thorough investigation of apparent policy violations can significantly reduce legal, compliance and reputational exposure.

When Can World Cup Hospitality Create FCPA Risk?
The FCPA prohibits covered persons and entities from offering, paying, promising or authorizing the provision of anything of value to a foreign official for the purpose of obtaining or retaining business or securing an improper advantage.

Covered persons include U.S. issuers (including public companies whose securities are traded in the United States); officers, directors, employees, agents and certain shareholders acting on behalf of issuers; U.S. citizens, nationals, residents and business entities organized under U.S. law (“domestic concerns”); and foreign persons who engage in FCPA violations while present in U.S. territory or via means of U.S. interstate and foreign commerce.

The FCPA defines “foreign official” broadly, covering not only ministers, regulators and government employees, but also officers and employees of state-owned and state-controlled enterprises and instrumentalities. For example, potentially covered recipients may include employees of state-owned energy companies, airlines, telecommunications providers, utilities, banks, healthcare providers, other commercial enterprises and sovereign wealth funds. Accordingly, what appears to be ordinary customer entertainment may implicate the FCPA if the recipient works for a state-owned or state-controlled entity.

Tickets, hospitality packages, travel, lodging, meals, transportation and exclusive event access all may constitute prohibited “things of value” under the FCPA. Whether a particular invitation creates risk depends heavily on the surrounding facts. A World Cup invitation provided to a state-owned-enterprise executive while a contract renewal is pending before that enterprise, for example, presents a heightened risk profile.

What Is FEPA and How Might It Apply?
Enacted in 2023, FEPA criminalizes certain conduct by foreign officials who corruptly demand, seek, receive, accept or agree to receive things of value in exchange for official action, which can include tickets, events and access in the World Cup environment. Because FEPA is relatively new, there has been limited public enforcement activity to date, and many questions remain regarding the scope and practical application of the statute. Nevertheless, prosecutors may view FEPA as a useful tool in appropriate cases.

The 2026 World Cup may create circumstances in which FEPA becomes particularly relevant. Unlike international business interactions that occur abroad, the tournament will bring foreign government officials, employees of state-owned enterprises, sovereign wealth fund personnel and procurement officials physically into the United States for an extended period. As a result, requests, demands, solicitations, meetings, communications, hospitality events and related conduct that might otherwise occur overseas may take place while the relevant official is present in U.S. territory, potentially strengthening the jurisdictional basis for U.S. enforcement.

When Could FARA Become Relevant?
FARA requires certain persons acting within the United States on behalf of a foreign principal—including foreign governments, political parties, and, in some circumstances, foreign companies—to register with the Department of Justice when engaging in specified political, public-relations, lobbying or influence-related activities.

FARA does not prohibit the provision of hospitality itself. Rather, it prohibits the failure to register or comply with FARA’s disclosure and reporting requirements when registration is required.

For most companies, World Cup hospitality will not implicate FARA. However, FARA issues may arise when an individual or firm acting on behalf of a foreign government or other foreign principal provides World Cup tickets, hospitality or related benefits to U.S. government officials, policymakers, political influencers, or other persons capable of shaping public policy or opinion, as part of a broader effort to advance the foreign principal’s interests in the United States. In those circumstances, organizations can monitor for FARA registration, disclosure or recordkeeping requirements.

Hospitality Risks in the Context of Federal and State Ethics Rules

Federal Ethics Rules
The federal gift rules contain an absolute prohibition that catches many organizations off guard: An employee of the executive branch is flatly prohibited from soliciting or accepting a gift from a “prohibited source” or a gift that is given because of the employee’s official position. U.S. House and Senate ethics rules mirror this strict status-based restriction. Members, officers and employees of Congress are barred from accepting gifts unless specifically permitted by an exception.

Consequently, offering premium items like World Cup tickets to a public official simply because they hold a specific regulatory, committee or procurement title violates the core of these federal bans. Even if the company has no active business before the official, providing high-value sports entertainment based entirely on their official status is a per se violation. Exceptions such as the Widely Attended Gathering (WAG) exception generally will not apply for World Cup tickets and surrounding events.

State Political Gift and Anti-Bribery Laws
State-level jurisdictions impose their own distinct—and frequently harsher—compliance rules. Many states operate under strict “zero-gift” or nominal-dollar thresholds (often capped between $10 and $25) for any gift, meal or entertainment provided by a registered lobbyist or an entity doing business with the state.

In addition, many states prohibit not only gifts that exceed specific monetary limits, but also gifts that create the appearance of attempting to influence an official’s judgment, secure favorable treatment or improperly affect governmental decision-making.

Because state definitions of a “gift” are broad and enforcement mechanisms are aggressive, an executive or business development team attempting to distribute high-value items like World Cup tickets across multiple states will routinely trigger prohibited-source thresholds and appearance-of-impropriety concerns, which can create significant civil and criminal exposure for both the donor and the recipient.

For entities doing or seeking to do business with a state, the consequences of offering an unlawful gift in certain circumstances can be severe, including the immediate termination or voiding of an existing government contract, automatic disqualification from a pending procurement process and lengthy periods of debarment that prohibit the entity from bidding on or performing future public-sector contracts.

States also may prohibit commercial bribery in addition to public-official bribery. For example, states may prohibit employees, agents, or fiduciaries from soliciting or accepting corrupt payments to benefit a third party without their employer’s knowledge or consent and may also penalize the individuals or businesses offering the bribes. These laws are not uniform, however, and specific offenses and penalties vary significantly across jurisdictions.

The Travel Act
The federal Travel Act may apply where travel or use of mail or facilities in interstate or foreign commerce is undertaken with the intent to promote, manage or facilitate an unlawful activity, followed by performance of an overt act in furtherance of the unlawful activity. The Travel Act permits federal prosecutors to pursue certain bribery schemes that rely on interstate or foreign commerce and involve violations of underlying state bribery laws. The statute has historically been employed in both public-sector and private-sector corruption prosecutions, often using underlying state-law violations as the trigger for Travel Act liability.

Thus, companies should not assume that anti-corruption concerns disappear merely because a recipient is employed by a private company rather than a government entity. For example, providing high-value hospitality to influence a private-sector procurement decision may create risk under state commercial bribery laws and, accordingly, the Travel Act, when its other jurisdictional prongs are satisfied.

Practical Considerations
Government investigations involving hospitality and entertainment often begin years after the underlying event. Whistleblower reports, competitor complaints, procurement disputes, audits, changes in management, cross-border cooperation or unrelated investigations may all bring historical hospitality practices under scrutiny. Statutes of limitations for relevant laws can stretch for five years or more and be extended by tolling or conspiracy charges.

Accordingly, to manage risk, before offering, approving, accepting or attending World Cup hospitality, companies can assess:

• Who is providing and receiving the hospitality?
• Is the recipient a government official or employee of a state-owned enterprise?
• Is any business, procurement, licensing, regulatory, tax, customs, enforcement or investment matter pending?
• What is the total value of the hospitality package?
• Does the package include travel, lodging, meals, transportation or guest attendance?
• Has a legitimate business purpose been documented?
• Have required compliance approvals been obtained?
• Will the expenses be accurately recorded?
• Would the arrangement withstand scrutiny from regulators, prosecutors, auditors, shareholders, journalists or competitors?

If potential issues are identified in connection with World Cup hospitality, organizations should be prepared to respond promptly. Responsible personnel should escalate concerns immediately, and reporting channels should be available.

Legal and compliance officials should be ready to preserve relevant records, assess exposure and, where appropriate, conduct a privileged internal review, which may warrant engaging legal counsel to identify and remediate potential violations of applicable law and company policy, and to assess whether reporting any identified misconduct may be appropriate, as a matter of contract disclosure obligations, regulatory requirements, responsibilities to auditors, or voluntary self-disclosure to enforcement authorities.

Companies may need to consider contractual disclosure obligations, regulatory reporting requirements, auditor communications or potential voluntary self-disclosure to enforcement authorities.

Conclusion
In most hospitality-related enforcement matters, the greatest risk often arises not from the ticket or event itself, but from inadequate controls, poor documentation, ignored warning signs or a failure to respond appropriately once concerns are identified. Organizations planning or participating in World Cup-related events can manage risk by approaching these activities with an expectation that those decisions may later be examined by enforcement authorities, regulators, auditors or litigants—and with additional information that may not have been apparent at the time. The most effective risk mitigation remains the same as in any anti-corruption context: careful recipient analysis, clear business justification, appropriate approvals, accurate recordkeeping and disciplined compliance oversight.