Flowerland, an American producer of orchids and bromeliads, operates a factory in China that produces ceramic pots in which its products are shipped. Recognizing the value of maintaining good relationships with the residents of the town, Flowerland donates several thousand dollars to a local children’s hospital each year, and is proud to have a wing of the facility named in its honor. Does the donation violate the FCPA? What if the director of the hospital is the wife of a local official who has the power to inspect—and potentially shut down—the factory for unsafe working conditions? What if that official had been the one to suggest the donation?