Platkos Inc., a U.S. company, applies for a permit to import its goods to Russia. A Russian official denies the permit. Platkos hires a Russian consultant, a very low level official, to act as a lobbyist. The consultant is paid a very large fee. When the permit is approved, Platkos sends the consultant a thank-you gift. Is this scenario permissible under the FCPA?

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The Answer of Platkos Inc., a U.S. company, applies for a permit to import its goods to Russia. A Russian official denies the permit. Platkos hires a Russian consultant, a very low level official, to act as a lobbyist. The consultant is paid a very large fee. When the permit is approved, Platkos sends the consultant a thank-you gift. Is this scenario permissible under the FCPA?