Mike’s Models Inc. is a modeling agency registered in Delaware, specializing in Central and South American women for print, runway, and other modeling work. The company’s manager of the Venezuelan territory, Jose, a Venezuelan citizen, has discovered Sonja and believes that she has the potential to be a superstar. Because permission for her to travel to the United States could take weeks and Mike’s want her for a car show in 10 days, Jose offers the head of Venezuelan immigration services the use of the company’s New York City penthouse and personal use of the company’s limousine the next time the official visits the United States for putting Sonja’s papers through quickly. The official turns him down. Has the Foreign Corrupt Practices Act been violated? Fully explain why or why not.
