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Which of these does NOT raise red flags for an improper gift, travel, or entertainment under the FCPA? A $17,000 trip to California for four

Which of these does NOT raise red flags for an improper gift, travel, or entertainment under the FCPA?

  1. A $17,000 trip to California for four government officials to tour facilities, classified internally as consulting, where the majority of time is spent at popular tourist attractions, such as Disneyland and Hollywood
  2. Payment of a country club membership for the government official responsible for approving or denying operating licenses for your company
  3. A 50$ painting from a local artist provided to a government procurement agent to reflect gratitude for an existing business relationship, permitted under local law and the company code of conduct.
  4. A night out with drinks and dinner for a procurement agent of a government-owned hospital, then a concert at a local club, as well as a private car for transportation around the city - costing a total of $5,000

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