Jenny Jones is a U.S. lawyer with the 400-lawyer firm Bigger & Best. Jones represents the government of the Republic of Sparta, a foreign country, in connection with foreign arbitrations, earning approximately $2 million per year in fees for her firm. Over the course of her work for this client, Jones has become friendly with a senior attorney in Sparta’s attorney general’s office. This attorney’s daughter suffers from a serious illness that cannot be treated in Sparta. To have a chance at a cure, the daughter will have to travel to Switzerland for treatment at a specialized clinic at a cost of $20,000. Knowing that the official doesn’t have the means to pay for the treatment, Jones wishes to pick up the tab. Her only goal is the wish to help a friend, and she will pay for the treatment entirely out of her personal funds. Both the government of Sparta and the leadership of Bigger & Best have expressly indicated that they have no objection to the proposed payment of medical expenses. Additionally, Jones has provided a certified letter from the Attorney General of Sparta, representing that Jones’ payment will have no impact on any future decisions about hiring outside counsel and that payment of these expenses would not violate any of the laws of Sparta. May Jones make this payment without running afoul of the FCPA?