Jack Zettler,a Resident of Germany,works as an Agent for Samson

Jack Zettler,a resident of Germany,works as an agent for Samson Enterprises,a U.S.company.Jack's job is to help negotiate steel rail contracts for Samson with the German government.Jack often takes German Department of Transportation officials out for beer or coffee to discuss Samson and its products.Which of the following statements is correct?

A) Jack has violated the FCPA by offering government officials something of value.
B) Jack may have violated German law, but Samson is not subject to the FCPA provisions when doing business in Germany.
C) Neither Jack nor Samson has violated the FCPA.
D) Only U.S.employees working in other countries can violate the FCPA.