Major Manufacturing Company is a large diversified international corporation whose shares trade on the New York Stock Exchange. The U.S. Department of Justice and the SEC have investigated the Global Oil Well Equipment Company, a subsidiary of Major. The agencies allege that Global has engaged in activities clearly in violation of the FCPA.

Tobias (Global president), Wilton (vice-president), and Clark (regional manager of operations in Nogoland) have conspired to make payments to influential members of Nogoland’s Parliament in order to influence legislation in Global’s favour. The agencies allege that Tobias, Wilton, and Clark met secretly in Geneva and decided to give inducements to Ms. Rock, the Speaker of Nogoland’s Parliament. They made a $750,000 loan to Ms. Rock’s manufacturing business at a 2% interest rate. They gave a $10,000 watch to Mr. Rock as a memento of the Rocks’ wedding anniversary. They paid Jenny Rock’s tuition to medical school. These expenditures were classified as investments, commissions, and promotion expenses in the Global financial statements. Their nature and purpose were not otherwise disclosed.

Required:

a. What provisions of the FCPA have apparently been violated by these actions by Global and its officers?

b. What penalties might be assessed on the corporation, if convicted? on Tobias, Wilton, and Clark?