Foreign Corrupt practices

Your new client is a publicly traded company in Chicago, Illinois, called Best New Products ("BNP"). It wants to establish a foreign subsidiary to manufacture and sell its products in a developing country. It hires a business consultant from the developing country who informs BNP that it is "customary" to pay substantial sums of money to procure the necessary business licenses.

In addition, BNP has been told it will need to pay a closing fee to the Minster of Foreign Trade. The consultant says that this is done all the time, it is part of the business and legal culture, nobody ever gets in trouble for it, and all of BNP's competitors regularly make this payment.

The consultant also says, "You can just put this amount in your books under 'closing costs.'"

The consultant also says, "Don't worry, I will handle everything, and I will be in the U.S. next week and can come pick up the necessary payments from your office."

Please advise BNP if any for the proposed actions may violate the Foreign Corrupt Practices Act.