A covered person is prohibited from making payments or offers/promises to pay any person while knowing all or part of that payment will be given directly or indirectly to any foreign official in an attempt to influence that official's actions.

Knowing means:

• Actual awareness
• A firm belief as to the existence of such circumstance, or that such circumstance will occur
• A high probability of the existence of such circumstance, unless the person “actually believes that such circumstance does not exist”

Willful blindness means the conscious disregard or deliberate ignorance of known circumstances that should alert one to anti-bribery and anti-corruption violations. Willful blindness is a violation of US anti-bribery and anti-corruption laws.