Your company is due a substantial tax refund from the local government of one of the countries where you operate. This amount is now 11 months overdue. The global CFO is under pressure to write off the amount, but such a write-down will wipe out your annual profit; employees will have to forgo their bonuses for no fault of theirs. It is becoming clear that without a payoff, this refund will not happen in a reasonable time. The demand is quite modest considering the magnitude of the refund. Most local firms and several multinational companies have quietly paid up. What should you do?

1. Does this violate the FCPA? Explain.

2. What should you do in this situation?