Engineering Solutions is competing for a contract to supply baggagehandling systems to a new airport being built in a developing nation. While the tender for bids is underway, the company flies the official charged with awarding the contract to the United States for a tour of some of the company’s systems installed at U.S. airports. The official flies business class and, while in the United States, is chauffeured by an executive limousine company. The company pays for all the official’s food and lodging expenses. Because the official is in the United States for a full week, the company pays for a $1,000/night suite at a Las Vegas casino over the weekend, justified by the fact that the Las Vegas airport uses the company’s system. Among other items from that weekend, the company pays a $2,000 tab that the official submits for dinner and drinks at Samantha’s Ranch Brothel, a legal house of prostitution located near Las Vegas. Has Engineering Solutions violated the FCPA?