This article examines the circumstances under which traditional authorities, such as aboriginal “band” (otherwise referred to as “tribal” or “traditional authority”) leaders, may qualify as “foreign officials” under the FCPA. This question is of particular importance to companies seeking to pursue mining interests in Canada, where numerous self-governing aboriginal communities (including First Nations, Me´tis and Inuit peoples) hold rights to mineral-rich areas, as well as to mining companies active in Africa, South America, and Australia.