But the Foreign Corrupt Practices Act is flexible, and even buying a positive reaction could be enough to violate the statute.
Did it violate the statute simply to conceal cash while crossing the border, as the courier, Regalado Cuellar, was convicted of doing?
"Simply 'overhearing' the conversation in the hallway is not likely a crime," said Joshua A. Douglas, a law professor at the University of Kentucky, but recording it "could violate the statute".
In a trip to Michigan by foreign officials to visit a company facility, for example, paying to take them to dinner, a baseball game and a play would not violate the statute.
It also argues that the presumed awards of $250,000 for the pain and suffering of each decedent's family are "woefully inadequate" and "violate the statute" because they do not take individual circumstances into account.
For example, the guidance says that it would not violate the statute if a company provided foreign officials, like employees of a state-owned electricity commission, promotional T-shirts at a trade show, picked up a bar bill or bought "a moderately priced crystal vase" as a wedding gift.
Federal investigators are looking at whether the payments violate the statute because of Alves' government and political roles in Macau, people familiar with the inquiry said.
Will their lawyers advise them to violate the statute and play along with the administration -- hoping Congress will bail them out in the future -- or will the lawyers tell them to "just say no" to illegal surveillance?
If anybody has the proof that the Bahrain Football Association has violated the statutes of Fifa or AFC, then present it.
