The correct answer is C. The CFE Manual explains that an FCPA bribery violation generally requires five elements: a regulated party makes a payment or offer to a foreign official, with corrupt intent, for the purpose of influencing a business purpose. A private U.S. company is a domestic concern and therefore a regulated party under the FCPA. A Chinese public official qualifies as a foreign official, and paying that official $45,000 to influence the award of contracts clearly reflects corrupt intent tied to obtaining business. That fits the FCPA framework directly.
Option A describes a required fee to conduct business, not necessarily a corrupt payment to a foreign official. Option B involves bribery of a private-sector person, but the Manual states that the FCPA applies to bribery of foreign government officials, not commercial bribery involving private entities. Option D is less clearly within U.S. FCPA jurisdiction because it involves a UK company; while some foreign entities can fall under the FCPA if they take acts in furtherance of the corrupt payment within U.S. territory, that fact is not stated here. Therefore, C is the clearest and most direct FCPA violation.
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