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Hunter's company is doing business in Russia and he secures a very large contract with a private company there, but the work and revenue won't

  1. Hunter's company is doing business in Russia and he secures a very large contract with a private company there, but the work and revenue won't commence until the next calendar year. After some other good contracts around the world, Hunter is very close to a huge year-end bonus, but really needs that Russian contract revenue to start coming in this year. He contacts the CEO of the Russian company and offers him $100,000 if they can start the contract and some of the payments in the current year. Would this payment be a violation of the Foreign Corrupt Practices Act? Explain why/why not.

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