Centurion Holdings, a U$.$S$.-$based multinational, is seeking to expand operations in Zembara, a developing nation with a complex regulatory environment. To facilitate a construction permit for a new manufacturing plant, Centurion$$s local agent, who is a Zembaran national, makes an unofficial $$expedited processing fee$$ payment of $$25,000$ to a mid$-$level official at Zembara$$s Ministry of Infrastructure. The payment is not recorded on the company$$s financial statements, and Centurion$$s U$.$S$.$ executives claim they were unaware of the payment at the time. Later, an internal audit reveals the payment, and the company self$-$reports to the U$.$S$.$ Department of Justice $($DOJ$).$ In its defense, Centurion argues that the payment was merely a $$grease payment$$ and customary in Zembara to move paperwork through red tape, not to influence any official decision.

Which of the following statements best reflects the ethical and$/$or legal implications under U$.$S$.$ law and business ethics frameworks?

Option A

The payment is clearly permissible under the FCPA because it qualifies as a grease payment and was made to expedite a routine government action, not to secure business.$$

Option B

Centurion can avoid liability under the FCPA if it demonstrates that its executives lacked actual knowledge of the payment.$$

Option C

Even if the payment were a grease payment, Centurion may still be liable under the FCPA's accounting provisions for failing to record it accurately.

Option D

Under Kantian ethics, the payment is morally permissible if it conforms to local customs and facilitates business efficiency.

Option E

The payment is legally and ethically defensible because it did not result in a competitive advantage and was reported voluntarily.