If a US Firm Invites Foreign Officials to an Industry Conference and Conference

If a U.S. firm invites foreign officials to an industry conference and pays for foreign officials to have a modest lunch at the conference, the Foreign Corrupt Practice Act (FCPA) would ________consider the lunch to be a facilitating payment and would ________consider the act to be illegal.

A) likely; likely
B) likely not; not likely
C) likely; not likely
D) likely not; likely