Payments made to or for the benefit of a foreign official and/or his or her family to obtain or retain business are NOT permitted if those payments are intended to:

• Influence an official act or decision
• Induce an official to perform, or not perform, acts in violation of official duties
• Secure an improper advantage
• Induce an official to influence acts of government

Such payments can violate anti-bribery and anti-corruption laws even if they are not related to a specific business opportunity.