This has confused me as well.  If the payment is legal locally, but 
prohibited under the FCPA (because it's considered a bribe), is there 
always a violation?

At 10:27 AM 10/12/2007, you wrote:
>Hi everyone,
>
>I have a question about the FCPA.  The FCPA prohibits payments to foreign 
>government officials in order to influence a governmental decision. I know 
>about the "rountine governmental action" exception.  But what if the 
>payment is legal under local law?  Is the FCPA violated then?
>
>I am getting conflicting answers to this question from a textbook and 
>other sources, and would appreciate your help! (I teach the topic tonight)
>
>Thanks,
>
>Robert
>
>Robert C. Bird
>Assistant Professor
>University of Connecticut
>email: [log in to unmask] <mailto:[log in to unmask]>
>View my research on my SSRN Author page:
>http://ssrn.com/author=56987 <http://ssrn.com/author=56987>
>