“Hospitalities” include meals, travel, lodging, entertainment, modest gifts, provided to foreign government officials -- may give rise to liability under the FCPA
“Reasonable and bona fide” expenses include expenses directly related to the promotion or demonstration of products or services, or the execution or performance of a contract with a foreign government or its agency
Lavish hospitalities typically viewed as improper payments under the FCPA
Repeated instances of meals and entertainment of lesser value suggestive of improper payments