Jockeycraft, an Irish company, manufactures sulkies—carts used in harness racing. Because the design is unconventional—the cart has a single shaft extending over the horse’s back instead of one on each side—the item needs approval from racing commissions of every track where it is used. The racing commission of Plattemata, a Latin American country, is comprised of five officials, three appointed by the president of the country and two by a confederation of private race tracks. The commission is authorized under law to establish regulations for competition and safety conditions at all racetracks in the country. The commission’s members are not paid for their services and continue to work in their day jobs. One day Ricardo Richards, the head of Plattemata’s racing commission, reaches Brendan Boyle, Jockeycraft’s CEO, on Boyle’s cellphone while Boyle is making an international connection at JFK Airport on a trip from Dublin to Mexico City. Richards lets it be known that the sulky will not receive approval in Plattemata unless Jockeycraft contributes to a charitable foundation that Richards has established for retired jockeys. Boyle tells the official that he will “see what we can do.” When he arrives in Mexico City, Boyle arranges for a wire transfer in the amount of $50,000 from Jockeycraft’s account at an Irish subsidiary of JPMorgan Chase bank, payable to Ricardo Richards’ personal bank account in Plattemata. The transfer carries the notation “charitable contribution.” Has Jockeycraft violated the FCPA?