John is a sales associate for Neptune Cyber Solutions, a manufacturer of medium-sized computer operating systems. John is overseas in the nation of Megalopia hoping to secure a contract with a large manufacturing firm. Because the firm has technology contracts with Megalopia's military, any contract with the manufacturer must be approved by the Defense Department of Megalopia. John makes a cash payment of $10,000 to the Megalopian representative who is negotiating the contract. Of this amount, $3,000 is to cover the standard published fee that the government charges for these approvals, $2,000 is for an additional $2,000 to be paid to the government officials to expedite the approval, and $5,000 is a "thank you" to the manufacturer's representative for choosing the Neptune system. The $2,000 for expediting the approval is consistent with what is customary in Megalopia to pay for an expedited approval. It is well known that the payments of bribes are persuasive in conducting international business. To prevent U.S. companies from engaging in this type of conduct, the U.S. Congress enacted the Foreign Corrupt Practice Act (FCPA). The FCPA makes it illegal for U.S. companies, their officers, directors, agents, or employees to bribe a foreign official, a foreign political party official, or a candidate for foreign political office. A bribe is illegal only where it is meant to influence the awarding of new business or the retention of continuing business activity. Has John violated the Foreign Corrupt Practices Act? IRAC format