Q. John is a sales associate for Neptune Cyber Solutions, a manufacturer of medium sized Computer operating systems. John is overseas in the nation of Megalopia hoping to secure a contract with a large manufacturing organization. Because the organization has technology contracts with Megalopia military, any contract with the manufacturer must be approved by the Defence Department of Megalopia. John makes a cash payment of $10,000 to the Megalopian representative who is negotiating the contract. Of this amount, $3,000 is to cover the Standard published fee which the government charges for these approvals, $2,000 is for an additional $2,000 to be paid to the government officials to expedite the approval also $5,000 is a "thank you" to the manufacturer's representative for choosing the Neptune system. The $2,000 for expediting the approval is consistent with what is customary in Megalopia to pay for an expedited approval.

Has John violated the Foreign Corrupt Practices Act?