Executive Order 13259: Designation of Public International Organizations for Purposes of the Securities Exchange Act of 1934 and the Foreign Corrupt Practices Act of 1977
President: George W. Bush
Designated the European Union, its listed institutions and instrumentalities, and Europol as public international organizations for the Foreign Corrupt Practices Act, bringing their officers, employees and representatives within the Act’s relevant foreign-official definitions.
Status: In effect.
Is Executive Order 13259 still in effect? Yes. Active; designation remains reproduced with the current FCPA provisions.
What does Executive Order 13259 do?
The order assigned these duties: Justice Department — Apply the designation in criminal FCPA investigations and enforcement; Securities and Exchange Commission — Apply the designation in civil FCPA and issuer-accounting enforcement.
Verified the EU, named institutions and Europol designation against the signed order. The guide limits the effect to the Foreign Corrupt Practices Act definitions identified in the order, not a blanket grant of immunity.
Before and after
Before the order
The FCPA already covered officials of designated public international organizations, but the EU institutions and Europol required the specific presidential designation used by the statute.
After the order
The designation became part of the FCPA’s statutory-note framework and remains reproduced with 15 U.S.C. § 78dd-1. DOJ and SEC guidance continues to explain that public-international-organization personnel fall within the foreign-official definition; the order does not confer broader treaty privileges or immunities.
Who had to do what
| Agency / office | Action | Timing / position |
|---|---|---|
| Justice Department | Apply the designation in criminal FCPA investigations and enforcement | In covered conduct and cases |
| Securities and Exchange Commission | Apply the designation in civil FCPA and issuer-accounting enforcement | In covered conduct and cases |
| Covered companies and persons | Treat relevant EU and Europol personnel as public-international-organization officials for FCPA analysis | Ongoing |
What happened next
EO 13259 signed.
EO 13259 made the EU and Europol designation.
Legal and source detail
How it works legally
The designation is limited by its own terms to the cited Securities Exchange Act and FCPA provisions. It does not decide whether an EU entity or Europol is an international organization for other statutes, and liability still depends on every element, exception and jurisdictional rule of the FCPA. No located court opinion invalidated or narrowed this designation.
Sources by type
If a source is unavailable, first check the cited publisher or another official repository. The cited publisher remains the authority.
Primary and official sources
Orders, laws, court records and official implementation material.
How we checked this
Last checked against the sources above on October 2, 2026. How we research →