Summary of FCPA. The FCPA makes it illegal for U.S. companies, their officers, directors, employees, agents, and any stockholders acting on their behalf, to bribe “Foreign Officials” (defined below). Improper gifts, payments, or offerings of “Anything of Value” (defined below) to Foreign Officials – even by distributors of Crosstex - could violate the FCPA and will not be tolerated by Crosstex.